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FCPA Freeze and Refocus: Is Enforcement Becoming a Tool to Promote U.S. Economic, Foreign Policy and National Security Interests?

On February 10, 2025, President Trump signed an executive order instructing the Attorney General of the United States to pause enforcement of the Foreign Corrupt Practices Act ("FCPA") and to issue updated guidelines for...more

SEC Charges Investment Adviser - Signaling Importance of Accurate Disclosure of AML Procedures

The U.S. Securities & Exchange Commission ("SEC") recently announced settled charges against an investment adviser for misrepresentations regarding its anti-money laundering ("AML") procedures and compliance failures. As we...more

DOJ to Evaluate AI Risk Management and Whistleblower Protections in Corporate Compliance Programs

Over the past year, the Department of Justice ("DOJ") has warned that it will seek stiffer sentences for offenses made significantly more dangerous by the misuse of artificial intelligence ("AI") and has asked the US...more

DOJ Launches New Whistleblower Pilot Program

In March 2024, we published an alert regarding Deputy Attorney General (“DAG”) Lisa Monaco’s announcement that the US Department of Justice (“DOJ” or the “Department”) intended to design and implement a new whistleblower...more

DOJ Doubles Down on Warnings Against AI Misuse

In February 2024, we published an alert concerning the increase in regulatory attention to "AI washing," or making unfounded claims regarding artificial intelligence ("AI") capabilities. Notably, on February 14, 2024,...more

SEC’s Focus on Off-Channel Communications Continues

On September 29, the US Securities and Exchange Commission ("SEC") brought its latest wave of enforcement actions related to "off-channel communications," charging 10 additional firms with failing to maintain employee...more

More Aggressive White Collar Enforcement Expected Under the Biden Administration

The first 100 days of President Biden's administration, not least its appointments to key leadership positions, suggest that it will investigate and pursue white collar cases much more aggressively than the Trump...more

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