The Department of Justice (“DOJ”) announced that it is stepping back from its hard-line approach to corporate cooperation credit in which a corporation was not eligible for credit unless it disclosed all relevant facts about...more
In 2012, Donald Trump called the Foreign Corrupt Practices Act (“FCPA”) “ridiculous” and a “horrible law” that made it more difficult for U.S. companies to compete abroad. While President Trump’s private thoughts on the FCPA...more
Welcome to the spring edition of our White Collar Watch. Hopefully by the time you are reading this, winter’s storms (finally?) are behind us.
2018 has gotten off to a busy start for our practice and attorneys. We look...more
5/1/2018
/ Anti-Corruption ,
Anti-Money Laundering ,
Certiorari ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Environmental Protection Agency (EPA) ,
False Claims Act (FCA) ,
Financial Institutions ,
FinTech ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Investigations ,
Lagos v United States ,
Qui Tam ,
Recordkeeping Requirements ,
SCOTUS ,
Securities and Exchange Commission (SEC)
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
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
7/25/2017
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Bribery ,
Compliance ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
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
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
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
3/11/2015
/ Books & Records ,
Bribery ,
Corporate Counsel ,
Disgorgement ,
Due Diligence ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Entities ,
Foreign Subsidiaries ,
Goodyear ,
Internal Controls ,
Popular ,
Securities and Exchange Commission (SEC) ,
Settlement
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