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DOJ Rolls Out Corporate Whistleblower Pilot Program

On August 1, 2024, the Department of Justice officially launched a three-year pilot program to reward whistleblowers who report corporate misconduct....more

FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more

DOJ Criminal Division Announces Pilot Program on Voluntary Self-Disclosure for Individuals

On April 15, 2024, the Criminal Division of the Department of Justice (DOJ) announced the Pilot Program on Voluntary Self-Disclosure for Individuals, providing transparency regarding the circumstances in which Criminal...more

DOJ Announces Pilot Whistleblower Rewards Program and Increased AI Enforcement

On March 7, 2024, Deputy Attorney General Lisa Monaco announced Department of Justice (DOJ) initiatives to incentivize whistleblowers with payouts from civil or criminal forfeitures and to integrate artificial intelligence...more

SEC Enforcement Actions Reflect Expansion of SEC’s AML Compliance Focus: Broker-Dealers, Investment Advisers, Registered...

The Securities and Exchange Commission (SEC) recently announced anti-money laundering (AML)-related charges against an individual registered representative for failing to escalate red flags of potentially suspicious activity,...more

United States V. Danske Bank: New Theory of Liability for Violation of US AML Standards

This Article discusses the recent plea agreement between the United States and Danske Bank. It argues that the Department of Justice has advanced a new and evolving theory of liability for foreign banks that access the U.S....more

DOJ Announces Significant Guidance on Compliance, Compensation, Communications and Cooperation

On March 3, 2023, as part of the rollout of several updates to its guidance on corporate compliance programs, the Department of Justice (DOJ) released a new policy aimed at incentivizing compliance-driven compensation and...more

Department of Justice Issues Voluntary Self-Disclosure Policy for Corporate Criminal Enforcement Applicable to U.S. Attorneys’...

On February 22, 2023, the Department of Justice (DOJ) issued a Voluntary Self-Disclosure Policy (VSDP) which, effective immediately, applies to all U.S. Attorneys’ Offices (USAOs) nationwide with respect to corporate criminal...more

The Corporate Crime Advisory Group Has Spoken: DOJ Revises Corporate Criminal Enforcement Policies

On September 15, 2022, the Department of Justice (Department) released a memorandum revising several key aspects of its corporate criminal enforcement policies. The new policy, titled Further Revisions to Corporate Criminal...more

A Look Ahead into Corporate Enforcement in the Biden Administration

Just one year after President Biden’s election, senior administration officials have signaled in public remarks that the federal government will amplify enforcement pressure on corporations and their employees through...more

COVID-19: Federal Regulators Provide Limited AML Relief in Coronavirus Response, and Limited Support for the Use of Technology in...

In this alert, we summarize recent guidance from federal regulators and self-regulatory organizations - including the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), the Office of...more

AML and Sanctions: 2017 Trends and Developments

Over the past year, regulators continued to actively examine compliance, introduce new and heightened requirements, recalibrate global priorities, and aggressively pursue enforcement. This report reviews recent trends and...more

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