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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

DOJ to Evaluate AI Risk Management and Whistleblower Protections in Corporate Compliance Programs

Over the past year, the Department of Justice ("DOJ") has warned that it will seek stiffer sentences for offenses made significantly more dangerous by the misuse of artificial intelligence ("AI") and has asked the US...more

DOJ & SEC Bring Enforcement Actions Against Short Sellers, Highlighting Continued Prevalence of Short Selling Against Public...

The US Securities and Exchange Commission (SEC) and the US Department of Justice (DOJ) recently announced parallel actions against an activist short seller and his firm, charging them with multiple counts of securities fraud....more

DOJ Launches New Whistleblower Pilot Program

In March 2024, we published an alert regarding Deputy Attorney General (“DAG”) Lisa Monaco’s announcement that the US Department of Justice (“DOJ” or the “Department”) intended to design and implement a new whistleblower...more

DOJ’s Novel Application of Insider Trading to 10b5-1 Plans Leads to Conviction

In April, we issued an alert discussing the U.S. Securities and Exchange Commission ("SEC") and Department of Justice’s ("DOJ") expansion of insider trading to 10b5-1 plans. On June 21, 2024, a federal jury in California...more

“Novel” or Not: the SEC and DOJ’s Expansion of Insider Trading to “Shadow Trading” and 10b5-1 Plans Survive Their Days in Court

On April 5, 2024, the U.S. Securities and Exchange Commission ("SEC") won a jury verdict in its first "shadow trading" insider trading action. Only a few weeks before this verdict, a court denied a motion to dismiss a...more

New Settlements Demonstrate the SEC’s Ongoing Efforts to Hold Companies Accountable for AI-Washing

In the past few months, we have published several alerts concerning the increase in regulatory attention to "AI washing," or making unfounded claims regarding artificial intelligence ("AI") capabilities.1 Senior officials at...more

DOJ Doubles Down on Warnings Against AI Misuse

In February 2024, we published an alert concerning the increase in regulatory attention to "AI washing," or making unfounded claims regarding artificial intelligence ("AI") capabilities. Notably, on February 14, 2024,...more

DOJ Announces Pilot Program to Pay Monetary Rewards to Whistleblowers

During the American Bar Association's 39th National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco announced the launch of the U.S. Department of Justice's (DOJ or the Department) pilot program to...more

Recent Regulatory Announcements Confirm Increased Scrutiny of “AI-Washing”

In December 2023, we published an alert concerning US Securities and Exchange Commission ("SEC") Chair Gary Gensler's warning to public companies against "AI washing" – that is, making unfounded claims regarding artificial...more

How to Manage the Risks of SPAC Securities Fraud Actions in 2022

In March 2021, White & Case published a client alert entitled "How SPACs Can Manage the Risks of White Collar Scrutiny." The article discussed the surge in interest and publicity surrounding "SPACs" (Special Purpose...more

How Digital Asset Innovators Can Manage the Risks of White Collar Scrutiny in the US

Described as the "Wild West" by SEC Chairman Gary Gensler, the meteoric rise of digital assets like cryptocurrencies has disrupted the traditional financial ecosystem. The wave of enforcement actions brought by federal and...more

Deputy Attorney General Announces Reinvigorated Focus on Corporate Crime

In her October 28, 2021 speech to the 36th ABA National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco emphasized that white collar crime is a top enforcement priority for the Department of Justice...more

More Aggressive White Collar Enforcement Expected Under the Biden Administration

The first 100 days of President Biden's administration, not least its appointments to key leadership positions, suggest that it will investigate and pursue white collar cases much more aggressively than the Trump...more

DOJ Global Corruption Efforts Beyond the FCPA

Although courts have reined in the application of the Foreign Corrupt Practices Act (FCPA) anti-bribery provisions in the past two years, the US Department of Justice (DOJ) shows no sign of scaling back its global...more

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