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
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 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
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 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
4/16/2024
/ 10b5-1 Plans ,
Affirmative Defenses ,
Department of Justice (DOJ) ,
Enforcement ,
Good Faith ,
Healthcare ,
Insider Trading ,
Intent to Defraud ,
Mergers ,
Non-Public Information ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
Third-Party
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
12/4/2023
/ Acquisitions ,
Anti-Money Laundering ,
Antitrust Division ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement ,
EU ,
France ,
Germany ,
Mergers ,
Money Laundering ,
Poland ,
Policies and Procedures ,
Policy Statement ,
Popular ,
Remediation ,
Restitution ,
Safe Harbors ,
Spain ,
Voluntary Disclosure
On October 30, 2023, the US Securities and Exchange Commission ("SEC") announced that it filed charges against SolarWinds Corp. ("SolarWinds" or the "Company") and its Chief Information Security Officer ("CISO") in connection...more
11/15/2023
/ Breach Notification Rule ,
Chief Information Security Officer (CISO) ,
Civil Monetary Penalty ,
Cyber Attacks ,
Cybersecurity ,
Disclosure Requirements ,
Enforcement ,
Fraud ,
Information Technology ,
Initial Public Offering (IPO) ,
Injunctive Relief ,
Insurance Industry ,
Internal Controls ,
Investors ,
Material Misstatements ,
Misleading Statements ,
NIST ,
Omissions ,
Popular ,
Publicly-Traded Companies ,
Reporting Requirements ,
Sarbanes-Oxley ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Software ,
Vulnerability Assessments
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
11/10/2023
/ Acquisitions ,
Antitrust Division ,
Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement ,
Mergers ,
Policies and Procedures ,
Policy Statement ,
Remediation ,
Safe Harbors