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Ten Takeaways from the DOJ Criminal Division’s New Playbook on White Collar Enforcement Priorities

On May 12, 2025, the U.S. Department of Justice ("the DOJ" or "the Department") unveiled its new playbook for prosecuting white-collar and corporate crime. DOJ announced enforcement priorities for the Criminal Division ("the...more

New Orders Lifting Bars Signal Shift by SEC

In recent months, the U.S. Securities and Exchange Commission has signaled a shift in its approach to applications to lift administrative bars that restrict participation in the securities industry. This suggests there is...more

SEC Enforcement 2.0: Chairman Atkins Has Arrived

Paul Atkins has taken the reins of the US Securities and Exchange Commission (SEC). After being confirmed by the Senate on April 9, Atkins officially began his tenure as SEC Chairman on April 21. His arrival is expected to...more

Evolution of AI Washing Enforcement: DOJ Enters the Picture

On April 9, the US Department of Justice and Securities and Exchange Commission announced parallel cases against the founder and former CEO of an artificial intelligence startup for allegedly misleading investors about his...more

DOJ Implements Major Changes to National Security Priorities

On February 5, 2025, President Trump's nominee to lead the Justice Department (the "Department"), Pamela Bondi, was confirmed by the Senate to serve as the U.S. Attorney General. Bondi immediately took action to reshape the...more

FCPA Freeze and Refocus: Is Enforcement Becoming a Tool to Promote U.S. Economic, Foreign Policy and National Security Interests?

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

Lessons Learned from DOJ’s First Money Laundering Plea by a Major Financial Institution

On October 10, TD Bank pleaded guilty to violations of the Bank Secrecy Act and conspiracy to commit money laundering. The plea agreement outlines the facts that led to the charges and the consequences the Bank and its parent...more

FinCEN Issues Final Sweeping AML Requirements for Registered Investment Advisers & ERAs

On August 28, 2024, FinCEN issued a long-awaited final rule meant to address illicit finance activities and national security threats in the asset management industry. The new rule imposes similar requirements on investment...more

SEC Continues Focus on Off-Channel Communications

On August 14, the U.S. Securities and Exchange Commission (“SEC”) announced yet another wave of enforcement actions related to widespread “off-channel communications,” charging an additional 26 firms with failing to maintain...more

Supreme Court rules SEC use of in-house tribunals is unconstitutional in potentially far-reaching decision

On June 27, 2024, the Supreme Court ruled in SEC v. Jarkesy that when the Securities and Exchange Commission (SEC) seeks civil penalties from defendants for securities fraud, the Seventh Amendment requires it to bring the...more

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

FinCEN Again Proposes Sweeping AML Requirements for Registered Investment Advisers & ERAs

On February 13, 2024, FinCEN proposed a long-awaited rule to combat illicit finance and national security threats in the asset management industry. The new rule would impose similar requirements on investment advisers that...more

SEC’s Focus on Off-Channel Communications Continues

On September 29, the US Securities and Exchange Commission ("SEC") brought its latest wave of enforcement actions related to "off-channel communications," charging 10 additional firms with failing to maintain employee...more

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