Philip Bezanson

Philip Bezanson

Bracewell LLP

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Supreme Court Decision in Salman

Yesterday, the Supreme Court confirmed a more expansive application of criminal insider trading violations when it unanimously affirmed the Ninth Circuit Court of Appeals decision in Salman v. United States. In doing so, the...more

12/7/2016 - Corporate Executives Criminal Convictions Dirks v SEC Insider Trading Personal Benefit SCOTUS Tippees Tippers US v Newman US v Salman

Attorney-Client Privilege in Washington State No Longer Applies When Employment Ends

In order to preserve the attorney-client privilege, counsel who conduct internal investigations begin employee interviews with an “Upjohn Warning”—a disclosure indicating that counsel represents the employer, not the...more

11/18/2016 - Attorney-Client Privilege Corporate Privilege Former Employee Internal Investigations Post-Employment Communications Upjohn Warnings WA Supreme Court

Second Circuit Rules that Federal Warrants Do Not Apply to Electronic Information Stored Overseas

On July 14. 2016, the Second Circuit ruled that the government cannot lawfully use a search warrant to compel access to consumer data stored by Microsoft Corporation (Microsoft) overseas. In its decision, the court overturned...more

7/19/2016 - Contempt Electronically Stored Information Email Extraterritoriality Rules Ireland Microsoft Motion to Quash Reversal Search Warrant Stored Communications Act

DOJ Announces First Declinations After Implementing FCPA Pilot Program

The U.S. Department of Justice (DOJ) issued its first set of public declinations since its April unveiling of a new self-reporting Foreign Corrupt Practices Act (FCPA) pilot program. On June 7, 2016, Akamai Technologies,...more

6/10/2016 - Bribery China Disgorgement DOJ FCPA Federal Pilot Programs Non-Prosecution Agreements Popular SEC Voluntary Disclosure

DOJ Launches FCPA Pilot Program to Promote Company Self-Reporting

In a speech delivered last Wednesday by Assistant Attorney General Leslie Caldwell, the Justice Department’s (“DOJ”) Criminal Division announced the launch of a new Foreign Corrupt Practices Act (“FCPA”) “pilot program” that...more

4/13/2016 - Cooperation Criminal Prosecution DOJ FCPA Federal Pilot Programs Federal Sentencing Guidelines Personal Liability Remediation Self-Reporting Voluntary Disclosure

Improved U.S. - Cuba Relations Create Potential FCPA Risks for U.S. Companies Looking to Do Business There

The normalization of relations between the United States and Cuba offers potential lucrative business opportunities for companies that are prepared to meet Cuba’s unique corruption risks. On December 17, 2014, President...more

4/7/2016 - Bribery Corporate Counsel Cuba FCPA Foreign Official TCPI Young Lawyers

VimpelCom's Global FCPA Settlement - A Multinational Resolution

The U.S. Department of Justice (DOJ), the U.S. Securities and Exchange Commission (SEC) and the Public Prosecution Service of the Netherlands (OM) announced a coordinated criminal and civil Foreign Corrupt Practices Act...more

2/26/2016 - Bribery Compliance Deferred Prosecution Agreements DOJ Enforcement Actions FCPA SEC Settlement Telecommunications VimpelCom

SEC and Hitachi Reach FCPA Settlement Over Corrupt Payments in South Africa

The U.S. Securities and Exchange Commission (SEC) recently announced a settlement with Hitachi, Ltd. over allegations that the company sold shares in a South African subsidiary to a front company for the African National...more

10/9/2015 - Bids Bribery Conflicts of Interest FCPA Federal Contractors Hitachi SEC South Africa

SEC: 2015 Examination Priorities – Cybersecurity Compliance and Controls

Registered broker-dealers and investment advisers received a stern warning to strengthen their cybersecurity programs or face further regulatory scrutiny. On September 15, 2015, the SEC announced a plan to sharpen its focus...more

9/21/2015 - Broker-Dealer Compliance Cybersecurity Data Breach Data Loss Prevention Incident Response Plans Investment Adviser OCIE Risk Assessment SEC SEC Examination Priorities Vendors

DOJ: Companies, Serve Up Your Executives!

On September 9, 2015, the Department of Justice (“DOJ”) issued an internal memorandum regarding individual accountability for corporate wrongdoing. The memo, authored by Deputy Attorney General Sally Quillian Yates, is aimed...more

9/11/2015 - Attorney Generals Corporate Executives Corporate Fraud Corporate Liability Criminal Investigations Criminal Prosecution DOJ Government Investigations Personal Liability White Collar Crimes

Second Circuit Overturns Insider Trading Convictions of Two Portfolio Managers

In a blow to the Southern District of New York’s impressive run of insider trading convictions, the United States Court of Appeals for the Second Circuit held yesterday that insider trading convictions require the government...more

12/12/2014 - Hedge Funds Illegal Tipping Insider Trading Material Nonpublic Information Portfolio Managers Securities Securities Fraud US v Newman

SEC Continues Crackdown on Investment Advisers

The Securities and Exchange Commission (SEC) is continuing to pursue enforcement actions that focus on the accuracy and comprehensiveness of economic benefit disclosures – both to clients and in public filings. ...more

9/5/2014 - Conflicts of Interest Disclosure Enforcement Actions Investment Adviser SEC

SDNY Judge Orders Microsoft to Produce Emails Stored Abroad

Chief Judge Loretta A. Preska of the U.S. District Court for the Southern District of New York affirmed Magistrate Judge James C. Francis IV’s opinion and ordered that the U.S. Department of Justice (DOJ) could compel...more

8/5/2014 - Discovery DOJ ECPA Electronically Stored Information Email Microsoft Popular

Second Circuit Says District Court Erred In Blocking SEC/Citigroup Settlement

The United States Court of Appeals for the Second Circuit yesterday vacated a closely-watched 2011 decision by U.S. District Court Judge Jed Rakoff rejecting a $285 million fraud settlement between Citigroup Inc. and the U.S....more

6/5/2014 - Chevron Deference Citigroup Collateralized Debt Obligations Consent Decrees Enforcement Enforcement Actions Interlocutory Appeals Judge Rakoff Popular Risk Management SEC SEC v Citigroup Settlement

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