Is Edward Snowden a Whistleblower?
Treasury proposed a new rule that would require investment advisers to establish an AML/CFT program and file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN (Proposed Rule). The Proposed Rule...more
On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more
On June 3, 2021, President Biden issued a National Security Memorandum establishing the fight against corruption both at home and abroad as a core United States national security interest and directing the development of a...more
On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more
On August 6, the U.S. Court of Appeals for the District of Columbia kept in place $50,000-per-day fines on three Chinese banks—whose identities are redacted—for refusing to comply with subpoenas issued by the Department of...more
As difficult as it is to pass laws, especially potentially controversial laws, sunset provisions on national security legislation provide an opportunity to re-assess effectiveness, impacts on privacy, and opportunity costs. ...more
Even today, most companies—even technology companies—do not think they have information that the U.S. Government wants or needs, particularly as it might relate to a national security investigation. The reality is that as...more
On June 4, 2015, President Obama and his administration signed into law the U.S.A. Freedom Act, which “reform[s] the authorities of the Federal Government to require the production of certain business records, conduct...more
Nearly two years ago, Edward Snowden, a contractor working with the U.S. National Security Agency (“NSA”), revealed startling details of widespread surveillance practices by the U.S. government into telephone and Internet...more
It seems like a new revelation about mass surveillance by the U.S. government and our allies occurs on an almost daily basis, each one more astounding than the last. Don’t be surprised if those jingling bells you hear on your...more