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Forced Enforcement? The Fine Line in the CFTC’s Approach to Market Manipulation

On 27 August 2024, a Swiss commodity trader entered into a settlement agreement for $48 million with the US Commodity Futures Trading Commission (“CFTC”) in relation to alleged market manipulation charges. This case, rooted...more

Digging for Trouble: The Double-Edged Sword of Decisions to Report Misconduct

On May 10, 2024, Romy Andrianarisoa, former Chief of Staff to the President of Madagascar, was convicted for soliciting bribes from Gemfields Group Ltd (Gemfields), a UK-based mining company specializing in rubies and...more

Greenwashing: Emerging Compliance and Cross-Border Legal Risks

Greenwashing, or the use of green ‘claims’ to improve a business’ or product’s environmental credentials with consumers, has come under significant scrutiny in recent years. Both the Advertising Standards Authority and the...more

OFAC Expands Recordkeeping Requirements, Mandates Electronic Filings

Last week, the Office of Foreign Assets Control (OFAC) announced an interim final rule which amends the recordkeeping and reporting requirements relating to the various economic sanctions programs it enforces. Notably, the...more

Beyond Whistleblowing: Additional Highlights From the Department of Justice at the 2024 ABA White Collar Conference

As we wrote earlier this month, the Department of Justice (DOJ) made significant news at the recent American Bar Association White Collar Conference. But the Department didn’t stop at announcing its pilot whistleblower...more

The Race to Report: DOJ Announces Pilot Whistleblower Program

In recent years, the Department of Justice (DOJ) has rolled out a significant and increasing number of carrots and sticks aimed at deterring and punishing white collar crime. Speaking at the American Bar Association White...more

The ENRC Saga – Not Just a UK Concern

On 21 December 2023, Mr Justice Waksman handed down his judgment in the second trial of the Eurasian Natural Resources Corporation (ENRC) saga. The judgment, along with its earlier companions, is extraordinary in many ways...more

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