On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the “Blanche Memorandum”) detailing new guidelines for the Department of Justice’s approach to investigating and enforcing the Foreign Corrupt...more
The rule imposes substantial new diligence, reporting, cybersecurity, and auditing obligations on companies.
On December 27, 2024, the U.S. Department of Justice (“DOJ”) issued a final rule implementing Executive Order...more
1/8/2025
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Advisory Opinions ,
Biden Administration ,
Compliance ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Department of Justice (DOJ) ,
Executive Orders ,
Final Rules ,
Foreign Entities ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
National Security ,
Notice of Proposed Rulemaking (NOPR) ,
Reporting Requirements ,
Risk Management ,
Sensitive Personal Information
Last week DOJ published an updated version of its guidance on the Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations (“Guidance”). These updates refresh the guidance originally issued in 2019,...more
On September 23, 2024, the U.S. Department of Justice (Department) announced that it had updated its guidance to prosecutors on how to evaluate the effectiveness of a corporation’s compliance program. The guidance, known as...more
Major FCPA Enforcement Action -
Including charges against the CEO and CFO for failing to prevent misconduct -
In one of the largest FCPA settlements in history, hedge fund Och-Ziff Capital Management Group LLC...more
12/23/2016
/ CEOs ,
Democratic Republic of Congo ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Hedge Funds ,
Japan ,
Libya ,
Och-Ziff ,
Penalties ,
Securities and Exchange Commission (SEC) ,
Settlement
Program Has Broad Reach -
On October 21, 2016, the Food and Drug Administration launched a webpage that contains an Allegations of Regulatory Misconduct Form to enable whistleblowers, competitors, and others to report...more
In one of the largest FCPA settlements in history, hedge fund Och-Ziff Capital Management Group LLC (“Och-Ziff”) recently resolved a long-running government inquiry by agreeing to $413 million in financial penalties and a...more
10/10/2016
/ Africa ,
Bribery ,
Deferred Prosecution Agreements ,
Democratic Republic of Congo ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Hedge Funds ,
Internal Controls ,
Investment ,
Libya ,
Och-Ziff ,
Popular ,
Private Equity Funds ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
Sovereign Wealth Funds
House Financial Services Committee Votes To Repeal And Replace Dodd-Frank -
On September 13th, the House Financial Services Committee approved the Financial CHOICE Act of 2016 to repeal and replace key parts of the 2010...more
10/5/2016
/ Broker-Dealer ,
Class Action ,
Commercial Real Estate Market ,
Consumer Financial Protection Bureau (CFPB) ,
Cyber Threats ,
Dodd-Frank ,
Enforcement Actions ,
Financial Institutions ,
FinTech ,
FSOC ,
OCC ,
Private Equity ,
Securities and Exchange Commission (SEC) ,
Whistleblowers
The Securities and Exchange Commission announced two settled enforcement actions against private equity fund advisers last week involving certain fee practices and potential conflicts of interest. Consistent with its...more
9/1/2016
/ Administrative Proceedings ,
Conflicts of Interest ,
Disclosure Requirements ,
Enforcement Actions ,
Excessive Fees ,
Investment Advisers Act of 1940 ,
Private Equity Funds ,
Registration Requirement ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Transparency