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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

FCPA under the New Administration

The single most frequently asked question by our international clients over the past several months is whether there will be changes in white collar prosecution priorities under the new administration, specifically with...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

SEC FCPA Enforcement Action against Goodyear and Investigation of Mondelez International Provide Valuable Lessons for U.S....

Action Item: The Securities and Exchange Commission’s enforcement action against Goodyear Tire & Rubber Company and its investigation of Mondelez International provide key lessons to U.S. companies seeking to acquire foreign...more

SEC FCPA Settlement Sends Wake-Up Call to Small and Medium-Sized Businesses

On July 28, 2014, Smith & Wesson Holding Corp. (“Smith & Wesson”), the firearms manufacturer based in Springfield, Massachusetts, agreed to resolve charges brought by the Securities and Exchange Commission (“SEC”) for...more

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