A perennial debate exists in the white-collar space: do the benefits of self-disclosure outweigh the risks associated with providing the government with a road map to the company’s purported violation? Consistently, the...more
The U.S. Federal Government through its Financial Crimes Enforcement Network (“FinCEN”) revised last year’s Advisory on the Use of the Financial System to Facilitate Ransom Payments. In short, the U.S. Government is...more
Companies that make or facilitate ransomware payments were given a strong reminder of their due-diligence and compliance obligations by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). ...more
The CARES Act pumped over two trillion dollars into the American economy, with much of that money going directly to individuals in the form of stimulus checks or to small businesses in the form of Paycheck Protection Program...more
Introduction - On April 30, 2020, the U.S. Department of Justice (“DOJ”) Money Laundering and Asset Recovery Section (“MLARS”) and the United States Attorney’s Office for the Eastern District of New York (“EDNY”) entered into...more
Throughout April 2020, the United States Department of Labor Occupational Safety and Health Administration (OSHA) released guidance and alerts regarding its enforcement efforts during the COVID-19 pandemic. These documents,...more