On October 3, the International Consortium of Investigative Journalists began reporting on millions of confidential documents relating to the financial activities of heads of state, international business leaders, and other...more
Enforcement authorities throughout the Americas continued investigations of fraud, corruption, and other misconduct across the region. Below are some of the highlights of the last quarter. ...more
5/28/2021
/ Brazil ,
Bribery ,
Corruption ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Markets ,
Foreign Corrupt Practices Act (FCPA) ,
Latin America ,
Mexico ,
Money Laundering ,
Popular ,
Venezuela ,
White Collar Crimes ,
Wiretapping
As 2020 drew to a close, enforcement authorities throughout the United States and the Americas continued to investigate fraud, corruption, and other misconduct across the region. In this newsletter, we highlight some...more
3/11/2021
/ Bank Secrecy Act ,
Brazil ,
Bribery ,
CFTC ,
Corporate Transparency Act ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Drug Trafficking ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Money Laundering ,
NDAA ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
Whistleblower Awards ,
Whistleblowers
As 2020 drew to a close, enforcement authorities throughout the United States and the Americas continued to investigate fraud, corruption, and other misconduct across the region. Below, we highlight some developments from...more
1/22/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Brazil ,
Bribery ,
CFTC ,
Consumer Protection Act ,
Corporate Transparency Act ,
Corruption ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Drug Trafficking ,
Ecuador ,
Enforcement Actions ,
Enforcement Authority ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Latin America ,
Mexico ,
Money Laundering ,
NDAA ,
Securities and Exchange Commission (SEC) ,
Sweden ,
Whistleblowers
As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more
12/23/2020
/ Anti-Money Laundering ,
Civil Monetary Penalty ,
Currency Transaction Reports (CTR) ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
FinCEN ,
Internal Revenue Code (IRC) ,
Limited Liability Company (LLC) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities Exchange Act ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury ,
Whistleblowers
The New York Department of Financial Services’ (DFS) cybersecurity regulation imposes significant requirements on financial services companies doing business in New York. DFS, which enforces the regulation, has remained...more
On September 6, 2018, the Conference of Western Attorneys General (“CWAG”), a bipartisan group of attorneys general from a majority of U.S. states, issued a Cybersecurity Safe Harbor Policy Working Paper (the “Paper”)...more
The European Data Protection Board (“EDPB”), established under the General Data Protection Regulation (“GDPR”), said in a statement that the use of so-called “cookie walls” should be prohibited under the proposed EU e-Privacy...more
The EU General Data Protection Regulation (“GDPR”) came into force on May 25, 2018. With so much recent focus on preparing for and meeting this deadline, there is no doubt that companies will have breathed a sigh of relief to...more
Beginning in September 2018 and continuing through January 2019, the Federal Trade Commission (“FTC”) will hold a series of up to 20 public hearings intended to inform its future policy approach to antitrust and consumer...more
On March 14, 2018, the House Committee on Oversight and Government Reform brought senior federal officials together to testify about the current state of federal government IT and modernization plans. The hearing featured...more
On December 6, 2017, the Financial Industry Regulatory Authority (“FINRA”) issued a report describing findings and observations from its member firm examination program (the “Report”)....more
n October 13, 2017, finance ministers and central bank governors of the Group of Seven (the “G-7”) released a report entitled Fundamental Elements for Effective Assessment of Cybersecurity for the Financial Sector. The G-7...more
On July 18, 2017, the UK’s House of Lords European Union Committee published a report on EU data protection standards and the impact on the U.K. in the wake of Brexit. The House of Lords’ report, entitled, Brexit: the EU data...more
Today’s global investigations frequently involve the cooperation of many government agencies in multiple countries. On July 18, 2017, the U.S. Court of Appeals for the Second Circuit handed down a decision creating a major...more
7/26/2017
/ Appeals ,
Compelled Testimony ,
Corporate Counsel ,
Criminal Convictions ,
Cross-Border ,
Enforcement Actions ,
Fifth Amendment ,
Financial Conduct Authority (FCA) ,
Foreign Jurisdictions ,
Indictments ,
Libor ,
Rabobank ,
UK
On June 13, 2017, the Senate Foreign Relations Subcommittee on East Asia, the Pacific, and International Cybersecurity Policy held a hearing entitled “State-Sponsored Cyberspace Threats: Recent Incidents and U.S. Policy...more
On April 19, 2017, professional services company Accenture released the results of its survey of security executives in the banking sector relating to cybersecurity strategy and priorities. The survey results and...more
On April 17, 2017, Federal Trade Commissioner Terrell McSweeny spoke at an event in Washington, D.C., hosted by New America’s Open Technology Institute about broadband privacy issues in the wake of the repeal of the Federal...more
As companies expand across borders and invest more heavily abroad, foreign enforcement authorities are following the example set by the U.S. Department of Justice and the U.S. Securities and Exchange Commission in directing...more
On January 18, 2017, during the final days of the Obama Administration, the Federal Communications Commission (“FCC”) released a white paper (the “FCC Paper”) on cybersecurity risk mitigation in communications networks. The...more
Continuing the trend of recent years, cybersecurity has remained at the top of the regulatory agenda for several federal and state agencies. For financial institutions, keeping track of the dizzying array of proposed...more
On October 17, 2016, the Federal Financial Institutions Examination Council (“FFIEC” or the “Council”) released a set of answers to frequently asked questions about its cybersecurity assessment tool (the “CAT”). The FFIEC, an...more
On August 29, 2016, MeriTalk, a public-private partnership that works on government Information Technology (“IT”) issues, released a report titled “Navigating the Cybersecurity Equation.” The report examines how federal...more
On July 25 and 26, 2016, industry stakeholders assembled in Arlington, Virginia, to participate in the Medical Device Cybersecurity Risk Mitigation Conference sponsored by Q1 Productions. The conference focused on the...more
On July 1, James Kurose, the Assistant Director for Computer and Information Science and Engineering Directorate at the National Science Foundation, and Keith Marzullo, the Director of the National Coordination Office for...more