The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
Exploring the AI and Crypto Intersection
The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
INTERPOL and Child Kidnapping Cases. What are INTERPOL’s Abilities and Limitations?
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The CFPB and State AGs Act Jointly Against Online Educational Company
Will the U.S. Have a GDPR? With Rachael Ormiston of Osano
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
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
A CD or not a CD, That is the Question… That the Auditors Should Have Answered - A headline-grabbing SEC enforcement action last week against BDO USA and several of its national partners may lead audit firms to insist on...more
On September 9, 2015, Sally Quillian Yates, the Deputy Attorney General, issued a memorandum announcing the Department of Justice’s (DOJ) new guidelines regarding its intensifying focus on individual wrongdoers in the context...more
In a move certain to attract the attention of corporate executives, the Department of Justice, on September 9, 2015, issued a new policy memorandum regarding the prosecution of individuals in corporate fraud cases. Titled...more