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Ten Takeaways from the DOJ Criminal Division’s New Playbook on White Collar Enforcement Priorities

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

Evolution of AI Washing Enforcement: DOJ Enters the Picture

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

A new sheriff in town? No time for complacency as the US pauses anti-corruption enforcement

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

DOJ Implements Major Changes to National Security Priorities

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

FCPA Freeze and Refocus: Is Enforcement Becoming a Tool to Promote U.S. Economic, Foreign Policy and National Security Interests?

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

Lessons Learned from DOJ’s First Money Laundering Plea by a Major Financial Institution

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

DOJ to Evaluate AI Risk Management and Whistleblower Protections in Corporate Compliance Programs

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

DOJ Recommends AI-Specific Sentencing Enhancement

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

“Novel” or Not: the SEC and DOJ’s Expansion of Insider Trading to “Shadow Trading” and 10b5-1 Plans Survive Their Days in Court

On April 5, 2024, the U.S. Securities and Exchange Commission ("SEC") won a jury verdict in its first "shadow trading" insider trading action. Only a few weeks before this verdict, a court denied a motion to dismiss a...more

New Settlements Demonstrate the SEC’s Ongoing Efforts to Hold Companies Accountable for AI-Washing

In the past few months, we have published several alerts concerning the increase in regulatory attention to "AI washing," or making unfounded claims regarding artificial intelligence ("AI") capabilities.1 Senior officials at...more

DOJ Doubles Down on Warnings Against AI Misuse

In February 2024, we published an alert concerning the increase in regulatory attention to "AI washing," or making unfounded claims regarding artificial intelligence ("AI") capabilities. Notably, on February 14, 2024,...more

DOJ Announces Pilot Program to Pay Monetary Rewards to Whistleblowers

During the American Bar Association's 39th National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco announced the launch of the U.S. Department of Justice's (DOJ or the Department) pilot program to...more

Recent Regulatory Announcements Confirm Increased Scrutiny of “AI-Washing”

In December 2023, we published an alert concerning US Securities and Exchange Commission ("SEC") Chair Gary Gensler's warning to public companies against "AI washing" – that is, making unfounded claims regarding artificial...more

A View from Abroad: Unpacking DOJ’s M&A Safe Harbor Policy, Part II

On October 4, 2023, United States Deputy Attorney General (DAG) Lisa Monaco announced a new Department of Justice (DOJ) Mergers & Acquisitions Safe Harbor policy that encourages companies to self-disclose criminal misconduct...more

Questions about the “Carrot” and “Stick” Remain: Unpacking DOJ’s new M&A Safe Harbor Policy, Part I

On October 4, 2023, United States Deputy Attorney General (DAG) Lisa Monaco announced a new Department of Justice (DOJ) Mergers & Acquisitions Safe Harbor policy that encourages companies to self-disclose criminal misconduct...more

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