General Business Criminal Law

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Expansion of Antitrust Enforcement Continues with Extradition

On April 4, 2014, the Department of Justice’s Antitrust Division announced its first successful extradition of a foreign national to the United States on antitrust charges. Romano Pisciotti, a citizen of Italy, has been under...more

Nursery Rhymes, A Chinese Proverb, The HP FCPA Enforcement And The Myth Of The Rogue Employee

As my friend and colleague Jay Rosen is want to remind us, he continually learns much about compliance and ethics from his Kindergarten-aged daughters. I submit that you need only look to children’s nursery rhymes in the...more

Anti-Corruption Digest - April 2014

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. Anti-corruption enforcement crosses boundaries like no other, so keeping up to date is more important than ever. In this digest, we draw together news of...more

DOJ’s Use of Expansive Legal Theories Broaden FCPA Jurisdiction

Enacted in 1977 in response to the revelation of widespread bribery of foreign officials by U.S. companies, the Foreign Corrupt Practices Act (“FCPA” or “the Act”) was “intended to halt those corrupt practices, create a level...more

Are High Frequency Traders Playing Fast and Loose With the Rules?

When high frequency trading (HFT) first crept into the public consciousness, it related to primarily to the question of whether rapid, computer driven trading posed risks to the safety and stability of the trading markets. ...more

Considerations For Insurers In The Aftermath Of The MetLife Consent Decree

MetLife Consent Decree - On March 26, 2014, the New York Department of Financial Services (the "DFS") entered into a consent decree ("Consent Decree") with MetLife, Inc. and its subsidiaries, American Life Insurance...more

BankinBits First Quarter Recap

The BankinBits blog, which discusses recent developments in the banking industry, has within the first quarter of 2014 addressed a diverse range of topics including banking services for the marijuana industry, the shuttering...more

Canadian Government Steps Up Enforcement of Economic Sanctions - Conviction under Special Economic Measures Act for attempted...

For the first time in over 20 years since the enactment of the Special Economic Measures Act (SEMA), an Alberta-based company was charged with violating this statute by attempting to export controlled goods valued at $15 to...more

Employer Loses WARN Affirmative Defenses In Class Action Due To Insufficient Description In Notice

Things seem to be going from bad to worse for defunct law firm Dewey & LeBoeuf. As criminal charges continue to loom for some former Dewey partners, the judge overseeing Dewey’s bankruptcy has now ruled that the firm cannot...more

This Week In Securities Litigation (Week ending April 17, 2014)

High speed trading continued to be a central focus in this shortened week with the markets closed on Friday. The New York Attorney General has reportedly issued subpoenas to three firms for information regarding their...more

Financial Regulatory Developments Focus - April 2014

In this issue: - Derivatives - Compensation - Regulatory Capital - Financial Services - Financial Crime - Excerpt from Derivatives: European Commission Consults on Definition...more

UK Deferred Prosecution Agreements Code of Practice Published

The Serious Fraud Office has issued a code of practice for deferred prosecution agreements, which are now available as an alternative to conviction for certain white-collar offences in the UK. ...more

For the first time Germany extradites former executive to the US on antitrust charges

Romano Pisciotti, an Italian national, was extradited from Germany in April 2014 to personally face criminal charges in the US for participating in a worldwide cartel. This is the first time an individual has been extradited...more

To Be a Criminal, You Have to Act Like a Criminal

Lawyers, compliance professionals and senior management at companies can be obsessive when it comes to the threat of criminal liability. Please do not get me wrong, I am not minimizing the risk of criminal prosecution, nor I...more

Charles Duross: FCPA reform, DOJ trials and the revolving door

What matters were you particularly proud to have been involved in during your time at the DoJ? I’m proud of all of it but I think there are probably a couple of specific matters that stand out in my mind. The first...more

HP, Three Subsidiaries Pay $108 Million To Settle FCPA Charges

The Russian, Polish and Mexican subsidiaries of Hewlett-Packard Company resolved criminal FCPA charges with the Department of Justice while the parent corporation settled with the SEC. ZAO Hewlett-Packard A.O., or HP Russia,...more

Germany's Foreign Anti-Corruption Efforts: Second-Tier No More

A March 2011 report by the Organization for Economic Cooperation and Development’s (OECD’s) Working Group on Bribery characterized Germany as assuming a “leading position” in the investigation and prosecution of foreign...more

Rogue CFO I- Introduction

Small, privately owned corporations deal with all types of challenges: competition, government regulations, recessions, rising cost of benefits for employees —the list is long. But one area that seems to be a persistent...more

Casino AML Compliance Update: Las Vegas Sands Corp. Places Macau Casino Junkets Under Increased Scrutiny.

On April 4, 2014, Bloomberg reported that the Las Vegas Sands Corp. (“Sands”) has increased its scrutiny of casino junket operators in Macau. The decision comes as casinos seek to meet the increased demands of federal...more

What Does the First-Ever Extradition on an Antitrust Charge Mean for the Auto Parts Investigation?

On April 4, 2014, the U.S. Department of Justice, Antitrust Division announced a milestone victory, having successfully litigated its first extradition for an alleged antitrust violation. Romano Pisciotti, an Italian national...more

DOJ Confirms, Once Again, That Compliance Plans Really Do Matter

DOJ Confirms, Once Again, That Compliance Plans Really Do Matter - On Thursday, March 20, 2014, Acting Assistant Attorney General Mythili Raman confirmed an inescapable truth regarding both corporate governance and...more

DOJ Scores First Antitrust Extradition: More to Come?

With Friday’s announcement of the first-ever extradition of a foreign executive on criminal antitrust charges to the United States, the US Department of Justice has won a major victory in its effort to prosecute and deter...more

The World in US Courts: Winter 2014: Orrick's Quarterly Review of Decisions Applying US Law to Global Business and Cross-Border...

The global law firm Orrick, Herrington & Sutcliffe LLP is pleased to announce the Winter 2014 issue of The World in US Courts: Orrick's Quarterly Review of Decisions Applying US Law To Global Business and Cross-Border...more

First Successful Extradition of Foreign National for Price-Fixing Violation

For the first time, the U.S. Department of Justice (DOJ) has successfully litigated an extradition of a foreign national on an antitrust charge. This extradition shows that the DOJ is still pursuing individuals it charged...more

New York DFS Obtains Substantial Settlement In Licensing Enforcement Action

On March 31, in an enforcement action with potential implications for a range of financial service providers, the New York State Department of Financial Services (DFS) announced that an insurance holding company agreed to pay...more

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