On May 12, 2025, Matthew Galeotti, the Head of the Criminal Division at the Department of Justice ("DOJ") issued a new white collar enforcement plan (“Enforcement Plan”) titled “Focus, Fairness, and Efficiency in the Fight...more
5/14/2025
/ Bribery ,
Compliance ,
Corporate Counsel ,
Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
The purpose of this paper is to show how the failure to monitor for and prevent off-channel communications poses risk to traditional depository institutions that are not subject to the jurisdiction of securities-law...more
1/22/2025
/ Banking Sector ,
Compliance ,
Cybersecurity ,
Data Privacy ,
Depository Institutions ,
Electronic Communications ,
Employee Monitoring ,
Employment Policies ,
Financial Institutions ,
Mobile Device Management ,
Mobile Devices ,
Regulatory Requirements ,
Risk Management ,
Risk Mitigation
On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more
7/25/2024
/ AML/CFT ,
Anti-Money Laundering ,
Anti-Terrorism Financing ,
Compliance ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Agencies ,
FinCEN ,
NCUA ,
NPRM ,
OCC ,
Proposed Rules ,
Suspicious Activity Reports (SARs)
The Securities and Exchange Commission (SEC) recently announced anti-money laundering (AML)-related charges against an individual registered representative for failing to escalate red flags of potentially suspicious activity,...more
On March 3, 2023, as part of the rollout of several updates to its guidance on corporate compliance programs, the Department of Justice (DOJ) released a new policy aimed at incentivizing compliance-driven compensation and...more
3/6/2023
/ Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
New Guidance ,
Risk Assessment ,
White Collar Crimes
On February 22, 2023, the Department of Justice (DOJ) issued a Voluntary Self-Disclosure Policy (VSDP) which, effective immediately, applies to all U.S. Attorneys’ Offices (USAOs) nationwide with respect to corporate criminal...more
On September 15, 2022, the Department of Justice (Department) released a memorandum revising several key aspects of its corporate criminal enforcement policies. The new policy, titled Further Revisions to Corporate Criminal...more
9/20/2022
/ Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Crimes ,
Corporate Culture ,
Corporate Misconduct ,
Corporate Monitoring ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Personal Liability ,
Voluntary Disclosure ,
White Collar Crimes
Just one year after President Biden’s election, senior administration officials have signaled in public remarks that the federal government will amplify enforcement pressure on corporations and their employees through...more
11/10/2021
/ Advisory Board ,
Biden Administration ,
CFTC ,
Compliance ,
Compliance Monitoring ,
Cooperation ,
Corporate Misconduct ,
Cryptocurrency ,
Cybersecurity ,
Department of Justice (DOJ) ,
Enforcement Authority ,
Enforcement Guidance ,
Enforcement Priorities ,
False Claims Act (FCA) ,
Federal Contractors ,
Federal Trade Commission (FTC) ,
Popular ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes ,
Yates Memorandum
In this alert, we summarize recent guidance from federal regulators and self-regulatory organizations - including the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), the Office of...more
4/28/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
CARES Act ,
Compliance ,
Coronavirus/COVID-19 ,
Financial Crimes ,
Financial Fraud ,
Financial Institutions ,
Financial Regulatory Agencies ,
Financial Stimulus ,
Paycheck Protection Program (PPP)