Texas Attorney General (AG) Ken Paxton announced that General Mills has agreed to remove petroleum-based artificial dyes from its cereals and school food products throughout the U.S. by summer 2026, and from its entire U.S....more
Effective January 2025, the Occupational Safety and Health Administration (OSHA) hiked the maximum fines for workplace safety violations. As an example, the maximum fine for a “serious” violation is now $16,550 per violation,...more
Statutes of limitations limit the time within which a defendant can be held liable for any type of alleged wrongdoing. Plaintiffs who do not pursue their rights within the limitations period will find the courthouse doors...more
On October 17, 2023, the Commodity Futures Trading Commission’s (“CFTC” or “Commission”) Division of Enforcement (“DOE”) released its latest enforcement advisory, providing guidance to CFTC staff on resolution of an...more
On August 23, 2023, the U.S. Securities and Exchange Commission (SEC) adopted new and amended rules under the Investment Advisers Act of 1940, as amended (the Advisers Act), to address what it perceives as certain conflicts...more
On February 22, 2023, the Department of Justice (DOJ) adopted a new policy that establishes a national standard for voluntary self-disclosure credit in corporate criminal enforcement actions brought by U.S. Attorneys’ Offices...more
On February 24, 2023, the US Department of Justice (DOJ) rolled out a corporate self-disclosure policy (the Policy) to be applied by all 93 US Attorneys’ Offices throughout the country. The details of the Policy—which...more
On January 17, Assistant Attorney General Kenneth A. Polite, Jr. delivered remarks at Georgetown University Law Center, during which he announced changes to the DOJ’s Criminal Division Corporate Enforcement and Voluntary...more
The Securities and Exchange Commission (“SEC”) recently issued its annual enforcement report, which analyzes enforcement patterns and emerging priorities in the fiscal year (“FY”) ending September 30, 2021. Challenges born in...more
In remarks this week at the SEC Speaks conference, new SEC Enforcement Director Gurbir Grewal said he’s bringing back admissions in SEC settled actions to help spur accountability. Most SEC actions are settled on a “neither...more
As we reported last month, the FAA is finally taking strong enforcement action against unruly passengers who disrupt air travel. Today, the FAA announced three new cases involving stiff penalties against such individuals. ...more
Jules Kroll is widely credited as the founder of the modern corporate investigations industry, and this episode goes behind the scenes of Jules’ career....more
What changes when an investigator leaves the public sector and joins the private sector? For Brian Cairl, senior managing director and director of investigations of the Americas, his toolkit from his time in law enforcement...more
The US Nuclear Regulatory Commission (NRC) Office of Investigations (OI) recently published its Office of Investigations Annual Report FY 2019, providing an overview of OI’s activities during the previous fiscal year. The...more
On Nov. 4, 2019, the Securities and Exchange Commission (SEC) filed an amended complaint against Collectors Café and its CEO, Mykalai Kontilai, to add charges against defendants for alleged violations of whistleblower...more
In Robare, the D.C. Circuit clarifies the negligence and willfulness standards under Sections 206 and 207 of the Act. On April 30, 2019, the United States Court of Appeals for the District of Columbia Circuit issued its...more
On April 30, 2019, the United States Court of Appeals for the District of Columbia Circuit vacated an aggregate $150,000 in fines that the U.S. Securities and Exchange Commission (“SEC”) had levied against an investment...more
Government attorneys now have additional discretion in False Claims Act (FCA) civil cases to award cooperation credit to a corporation that meaningfully assists the government’s investigation without necessarily identifying...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
Conduct Performed Without Knowledge Still Can Lead to the Most Serious Penalties - Under the Bank Secrecy Act (“BSA”), the most onerous civil penalties will be applied for “willful” violations....more
On April 7, the FCC issued a Notice of Apparent Liability (“NAL”) against a wireless Lifeline provider, Total Call Mobile, Inc. (“Total Call”). An investigation conducted by the Universal Service Administrative Company...more
This week would have marked the return of Tom Brady, had his four game suspension not been reversed by the United States District Court for the Southern District of New York. Much ink has been spilled over Brady’s suspension...more
Securities and Exchange Commission members Daniel M. Gallagher and Luis A. Aguilar will soon leave the SEC, but neither is keeping quiet about the SEC’s treatment of chief compliance officers (CCOs). Gallagher recently...more
The U.S. Department of Justice (DOJ) recently issued a memorandum ("The Yates memo") on September 9, 2015 by Deputy Attorney General Sally Yates, reaffirming the Government's commitment to prosecuting individuals. Say...more
On September 9, 2015, Deputy Attorney General Sally Yates of the United States Department of Justice (“DOJ” or the “Department”) issued a new policy memorandum (the “Yates Memo”) entitled “Individual Accountability for...more