The Financial Crimes Enforcement Network (FinCEN) issued an interim final rule in March 2025 that removes requirements for US companies to report beneficial ownership information under the Corporate Transparency Act (CTA)....more
7/8/2025
/ Artificial Intelligence ,
Beneficial Owner ,
Compliance ,
Corporate Governance ,
Corporate Transparency Act ,
Cryptocurrency ,
Cybersecurity ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Financial Crimes ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
NYDFS ,
Popular ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
White Collar Crimes
On June 10, 2025, the head of the Criminal Division of the Department of Justice (DOJ), Matthew Galeotti, declared in a speech that the DOJ would resume enforcing the Foreign Corrupt Practices Act (FCPA). This announcement...more
On May 12, 2025, the Department of Justice (“DOJ” or the “Department”) issued a revised Corporate Enforcement and Voluntary Self-Disclosure Policy (Revised CEP). Matthew R. Galeotti, chief of the Criminal Division of the DOJ,...more
On Feb. 10, President Donald Trump issued an executive order pausing enforcement under the Foreign Corrupt Practices Act (FCPA or the Act) for a period of at least 180 days and up to 360 days. The order directs Attorney...more
As 2025 begins, we cover several significant corporate governance developments that occurred in the second half of 2024 and since our Corporate Governance: 2024 Midyear Review was published in August. We first highlight...more
On March 30, federal regulators announced that Wells Fargo Bank had entered into settlements in which it agreed to pay $97.8 million in fines for enabling sanctions violations between 2010 and 2015. In two separate...more
Eager to enlist corporations as “allies in [its] fight against crime,” the Department of Justice (DOJ) announced on Tuesday, Jan. 17, 2023, expansions to the Criminal Division’s corporate enforcement policy, now the Criminal...more
Over the course of the year — and even dating back to his time on the campaign trail — President Biden and senior officials in his administration, including Department of Justice (DOJ) and Security and Exchange Commission...more
12/21/2021
/ Anti-Corruption ,
Biden Administration ,
Bribery ,
Compliance ,
Corporate Counsel ,
Corporate Governance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Popular ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
In a recent speech at the Practising Law Institute’s annual SEC Speaks conference, Gurbir Grewal, the new director of the Division of Enforcement for the Securities and Exchange Commission (SEC or Commission), signaled...more
On Sept. 27, 2021, the U.S. Court of Appeals for the Second Circuit rejected the most recent legal challenge to the Securities and Exchange Commission’s (SEC) practice of using “no-deny” consent agreements to resolve civil...more
On Sept. 14, 2021, the Securities and Exchange Commission (SEC) entered a cease-and-desist order against App Annie Inc. and its co-founder and former CEO, Bertrand Schmitt, after agreeing to settle securities fraud claims....more
Introduction -
On Feb. 2, 2021, the Securities and Exchange Commission (SEC) issued a cease-and-desist order settling charges against the former CEO and CFO of WageWorks Inc. (WageWorks, or the Company), stemming from the...more
2/22/2021
/ Cease and Desist Orders ,
Compensation & Benefits ,
Corporate Counsel ,
Dodd-Frank ,
Enforcement Actions ,
Executive Compensation ,
Financial Statements ,
Incentive Compensation ,
Reimbursements ,
Sarbanes-Oxley ,
Section 304 ,
Securities and Exchange Commission (SEC) ,
Securities Violations
Three years ago, in a footnote to its unanimous opinion in Kokesh v. S.E.C., the Supreme Court left open two questions: “whether courts possess authority to order disgorgement in SEC enforcement proceedings” and “whether...more
In a speech delivered on Thursday, Nov. 29, 2018, Deputy Attorney General Rod Rosenstein described important changes to DOJ policies for awarding cooperation credit in corporate investigations. These changes have been...more
12/4/2018
/ Cooperation Agreement ,
Corporate Investigations ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Individual Accountability ,
Policy Statement ,
White Collar Crimes ,
Willful Misconduct ,
Yates Memorandum
On June 26, 2017, the D.C. Circuit, en banc, split 5-to-5 on whether to grant a petition seeking to overturn an August 2016 ruling by a three-judge panel of the D.C. Circuit that determined that SEC administrative law judges...more
In a pair of decisions issued on June 5, the Supreme Court sharply curtailed the scope of financial sanctions available in civil securities enforcement and criminal drug trafficking cases. In addition to the results, which...more
6/9/2017
/ Disgorgement ,
Enforcement Actions ,
Financial Services Industry ,
Forfeiture ,
Forfeiture Statutes ,
Honeycutt v. United States ,
Investment Management ,
Joint and Several Liability ,
Kokesh v SEC ,
Misappropriation ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Statute of Limitations ,
White Collar Crimes