The increasing use of AI-enabled meeting tools means that organizations are no longer dealing with a single minutes document, but a complex ecosystem of recordings, machine transcripts, AI summaries, decks and conventional...more
As the Trump Administration’s America First trade policy and reciprocal trade agreements continue to take shape, the DOJ is gearing up for increased criminal and civil enforcement of customs and tariff violations. In the...more
The SEC has launched a new task force to combat fraud involving foreign-based companies. The task force will focus on market manipulation schemes like “pump-and-dumps” involving Chinese and other foreign issuers. These...more
The Financial Action Task Force ("FATF") has published a new edition of its Comprehensive Update on Terrorist Financing Risks. The 2025 update presents a sobering analysis of current terrorist financing ("TF") threats and...more
9/4/2025
/ AML/CFT ,
Compliance ,
Cryptocurrency ,
Digital Assets ,
Due Diligence ,
FATF ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
Risk Management ,
Terrorist Financing Regulations
Although most reporting on the DOJ's latest Foreign Corrupt Practices Act (FCPA) guidelines has emphasized the anticipated reduction in overall anti-corruption enforcement, an equally important, but less noted, aspect has...more
On June 10, 2025, the Department of Justice (“DOJ”) issued a memorandum establishing guidelines for enforcement of the Foreign Corrupt Practices Act (the “Guidelines” and “FCPA,” respectively). The DOJ issued the Guidelines...more
On May 12, 2025, the U.S. Department of Justice ("the DOJ" or "the Department") unveiled its new playbook for prosecuting white-collar and corporate crime. DOJ announced enforcement priorities for the Criminal Division ("the...more
In recent months, the U.S. Securities and Exchange Commission has signaled a shift in its approach to applications to lift administrative bars that restrict participation in the securities industry. This suggests there is...more
Paul Atkins has taken the reins of the US Securities and Exchange Commission (SEC). After being confirmed by the Senate on April 9, Atkins officially began his tenure as SEC Chairman on April 21. His arrival is expected to...more
4/22/2025
/ Artificial Intelligence ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Private Funds ,
Regulatory Reform ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Technology Sector
On April 9, the US Department of Justice and Securities and Exchange Commission announced parallel cases against the founder and former CEO of an artificial intelligence startup for allegedly misleading investors about his...more
4/18/2025
/ Artificial Intelligence ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Fraud ,
Investors ,
Misleading Statements ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Regulation ,
Technology Sector
A new anti-bribery and corruption alliance among enforcement authorities in the UK, France and Switzerland sends a clear message to corporates that any pause in enforcement of the US FCPA does not mean that acts of bribery by...more
On February 5, 2025, President Trump's nominee to lead the Justice Department (the "Department"), Pamela Bondi, was confirmed by the Senate to serve as the U.S. Attorney General. Bondi immediately took action to reshape the...more
On February 10, 2025, President Trump signed an executive order instructing the Attorney General of the United States to pause enforcement of the Foreign Corrupt Practices Act ("FCPA") and to issue updated guidelines for...more
2/13/2025
/ Anti-Corruption ,
Attorney General ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Legislative Agendas ,
National Security ,
Regulatory Agenda ,
Trump Administration ,
White Collar Crimes
The U.S. Securities & Exchange Commission ("SEC") recently announced settled charges against an investment adviser for misrepresentations regarding its anti-money laundering ("AML") procedures and compliance failures. As we...more
1/29/2025
/ AML/CFT ,
Anti-Money Laundering ,
Compliance ,
Disclosure Requirements ,
Enforcement Actions ,
Financial Crimes ,
FinCEN ,
Investment Adviser ,
Penalties ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC)
2024 marks the final year of Gary Gensler's term as Chair of the U.S. Securities and Exchange Commission ("SEC"). The Gensler SEC has been aggressive on both the enforcement and rulemaking fronts. In response, the financial...more
12/23/2024
/ Artificial Intelligence ,
Capital Markets ,
Cryptocurrency ,
Cybersecurity ,
Disclosure Requirements ,
Enforcement ,
Enforcement Priorities ,
Financial Markets ,
Fund Managers ,
Gary Gensler ,
Insider Trading ,
Investment Management ,
Machine Learning ,
Pay-To-Play ,
Presidential Nominations ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Rulemaking Process ,
SCOTUS ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
Technology Sector ,
Trump Administration ,
Whistleblower Protection Policies
On October 10, TD Bank pleaded guilty to violations of the Bank Secrecy Act and conspiracy to commit money laundering. The plea agreement outlines the facts that led to the charges and the consequences the Bank and its parent...more
Over the past year, the Department of Justice ("DOJ") has warned that it will seek stiffer sentences for offenses made significantly more dangerous by the misuse of artificial intelligence ("AI") and has asked the US...more
An accelerating focus on doing business responsibly will force changes to wide-ranging aspects of business operations and strategy -
Societal expectations of businesses have shifted fundamentally over the past five years....more
9/27/2024
/ Business Operations ,
Business Strategies ,
Climate Change ,
Corporate Governance ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
EU ,
Litigation Strategies ,
Regulatory Agenda ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
SFDR ,
Sustainable Finance
On August 28, 2024, FinCEN issued a long-awaited final rule meant to address illicit finance activities and national security threats in the asset management industry. The new rule imposes similar requirements on investment...more
9/17/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Broker-Dealer ,
Exempt Reporting Advisers (ERAs) ,
Final Rules ,
Financial Crimes ,
FinCEN ,
Investment Adviser ,
National Security ,
Registered Investment Advisors
In early 2024, we published alerts on separate sets of remarks from Department of Justice ("DOJ") Deputy Attorney General Lisa Monaco warning that the DOJ would be seeking stiffer sentences for offenses made significantly...more
On July 18, 2024, a New York federal judge dismissed most of the US Securities and Exchange Commission’s ("SEC") claims against SolarWinds Corp. ("SolarWinds" or the "Company") and its Chief Information Security Officer...more
On June 27, 2024, the Supreme Court ruled in SEC v. Jarkesy that when the Securities and Exchange Commission (SEC) seeks civil penalties from defendants for securities fraud, the Seventh Amendment requires it to bring the...more
7/2/2024
/ Administrative Authority ,
Administrative Law Judge (ALJ) ,
Administrative Proceedings ,
Constitutional Challenges ,
Enforcement Actions ,
Jury Trial ,
SCOTUS ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Regulation ,
Separation of Powers ,
Seventh Amendment
In February 2024, we published an alert discussing the significant benefits of prompt self-reporting and cooperation during a US Securities and Exchange Commission ("SEC") investigation. This past week, during his keynote...more
On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more
5/21/2024
/ AML/CFT ,
Anti-Money Laundering ,
Asset Management ,
Bank Secrecy Act ,
Broker-Dealer ,
BSA/AML ,
Comment Period ,
FinCEN ,
Investment Adviser ,
New Rules ,
Public Comment ,
Registered Investment Advisors ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Assessment ,
Risk Management ,
Securities and Exchange Commission (SEC)
Over the past few months, the Securities and Exchange Commission (the "SEC") has issued several warnings to companies to ensure accurate disclosure of the role and risks of artificial intelligence ("AI") in their businesses....more