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Comments by Deputy Attorney General Rod Rosenstein Suggest Major Changes to Department of Justice Policies May Be Coming

Historically, the U.S. Department of Justice (“DOJ”) often articulated policy decisions by issuing department-wide memos, usually named for their authors. For instance, in 2015, the DOJ announced a policy of holding...more

White Collar Watch (July 2017 • Vol 1, Issue 2)

Welcome to the summer edition of Blank Rome’s White Collar Watch. In a world that seems to bring new challenges daily—such as the global cybersecurity attacks that were launched in late June—this newsletter is designed to...more

At the Intersection of Cybersecurity and White Collar

The global "ransomware" cyberattack in early May 2017 resulted in tens of thousands of computer systems being taken hostage by hackers and, in the instances involving hospitals, put lives at risk. Companies that suffered...more

In Rare Victory for Corporations, Supreme Court Limits SEC Power with Significant Implications for FCPA Settlements

Action Item: Last week’s Supreme Court of the United States decision in Kokesh v. SEC will significantly limit the Securities and Exchange Commission’s (“SEC”) ability to collect disgorgement for violations of the Foreign...more

New York Department of Financial Services Implements New “First-in-the-Nation” Cybersecurity Regulations

As of March 1, 2017, New York financial institutions subject to the oversight of the New York Department of Financial Services (“DFS”) are required to comply with a new cybersecurity regulatory scheme. Compliance deadlines...more

U.S. Department of Justice Issues New Guidance on Corporate Compliance Programs

Action Item: The U.S. Department of Justice Criminal Division, Fraud Section (“DOJ”), recently published new guidance on corporate compliance programs. All corporate counsel, officers, and directors should be aware of this...more

New York Proposes Tough New Anti-Money Laundering and Cybersecurity Measures on Financial Services Companies

Action Item: Benjamin Lawsky, the Superintendent of Financial Services for New York State, one of the country’s most aggressive regulators, is seeking to increase regulatory pressures on the financial services industry,...more

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