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SDNY Launches Whistleblower Pilot Program to Encourage Self-Disclosure of Criminal Conduct

The recently created SDNY Whistleblower Pilot Program encourages individuals to self-disclose certain criminal conduct and cooperate in resulting investigations and prosecutions. ...more

Considerations for Addressing DOJ’s Corporate Compliance Guidance on Mobile Devices and Messaging Platforms

In light of the DOJ’s most recent guidance on the use of personal devices and third-party messaging applications by corporate personnel, this White Paper addresses issues and challenges that companies are facing in this area...more

Federal Agencies Coordinate Action Against Celsius for Fraud and Manipulation

In Short - The Situation: In parallel federal actions, the Department of Justice ("DOJ"), Securities and Exchange Commission ("SEC"), Commodity Futures Trading Commission ("CFTC"), and Federal Trade Commission ("FTC")...more

Cryptocurrencies and Risk Under the Antiterrorism Act

In Short - The Situation: Terrorists may be increasingly turning to cryptocurrencies to evade sanctions and finance terrorist acts, as recent prosecutions and reports suggest. Under the Antiterrorism Act ("ATA"), as...more

DOJ Announces New Voluntary Self-Disclosure Policy for All U.S. Attorneys' Offices

On February 22, 2023, the U.S. Department of Justice ("DOJ" or "Department") announced the Voluntary Self-Disclosure Policy ("VSD Policy" or "Policy"), detailing the circumstances under which a company can receive credit for...more

FCPA 2022 Year in Review

Foreign Corrupt Practices Act (“FCPA”) enforcement has yet to rebound from the immediate pre-pandemic period. In 2022, DOJ and SEC resolved eight corporate FCPA matters for $878 million, including four resolutions coordinated...more

First Corporate Anti-Terrorism Act Prosecution Marks Expansion of U.S. Counterterrorism Efforts

In Short - The Situation: In October 2022, the U.S. Department of Justice ("DOJ" or "Department") announced a guilty plea in its first-ever corporate "material support" prosecution under 18 U.S.C. § 2339B of the...more

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