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Holland & Knight LLP

CFTC, DOJ and SEC Announce First Coordinated Action Aimed at Voluntary Carbon Market Fraud

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On Oct. 2, 2024, the Commodity Futures Trading Commission (CFTC), U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC) announced parallel actions against CQC Impact Investors LLC (CQC or the...more

Husch Blackwell LLP

False Claims Act Insights - Are the FCA’s Qui Tam Provisions Unconstitutional? One Federal Judge Says “Yes

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Host Jonathan Porter is joined by Husch Blackwell partners Jody Rudman and Lorinda Holloway to discuss the implications of a September 2024 federal court decision from the Middle District of Florida that strikes down the...more

Morrison & Foerster LLP - Government...

Ninth Circuit Sits En Banc To “Tidy Up The Law” On The False Claims Act’s First-To-File Rule

In September 2024, the Ninth Circuit reversed in part a district court’s dismissal of an action under the False Claims Act (FCA or the “Act”) for lack of jurisdiction under the Act’s First-to-File Rule and held that the...more

Wiley Rein LLP

DOJ Urges the D.C. Circuit to Permit Retroactive FARA Registrations

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The U.S. Department of Justice (DOJ) recently filed a petition in the U.S. Court of Appeals for the District of Columbia Circuit for a rehearing en banc in the Steve Wynn case, asking the D.C. Circuit to reconsider U.S. v....more

Pillsbury Winthrop Shaw Pittman LLP

DOJ Debuts Updates to Its Evaluation of Corporate Compliance Programs Aimed at the Responsible Use of Artificial Intelligence

On September 23, 2024, the U.S. Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs (ECCP) guidance to instruct prosecutors on how to evaluate corporate risk related to the management and use...more

Baker Botts L.L.P.

CFTC, SEC, and SDNY Break New Ground and File Charges Against Carbon Credit Project Developer and Former Executives for Fraudulent...

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On October 2, 2024, the Commodities Futures Trading Commission (“CFTC”), the Securities and Exchange Commission (“SEC”), and the United States Attorney’s Office for the Southern District of New York announced parallel...more

Jones Day

NDIL Launches Pilot Program to Encourage Individual Self-Disclosure of Organizational Misconduct

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The Development: On September 16, 2024, the U.S. Attorney's Office for the Northern District of Illinois ("NDIL") announced its six-month Individual Self-Disclosure Pilot Program for Organizational Misconduct ("Pilot...more

Womble Bond Dickinson

The Challenge of Fair Trials in the Age of Media Saturation

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Social media’s influence on American society carries major implications for the public’s perception of current events. With headlines reaching millions of consumers within minutes, public outrage over racially charged crimes,...more

Ballard Spahr LLP

FinCEN Reports Check Fraud Amounting to $688 Million Over Six Month Period

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The Financial Crimes Enforcement Network (“FinCEN”) issued last month an in-depth report on check fraud stemming from mail theft (“Report”).  This is a pernicious and expanding problem.  The Report follows upon a joint alert...more

Cozen O'Connor

New York Note: More Adams Charges, Aide Resignation, Arts & Culture Power 100, Client Spotlight

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Prosecutor Suggests More Charges for Adams, Others - In a hearing last week, federal prosecutor Hagan Scotten said before a judge that additional charges are “possible” for Mayor Eric Adams and that it is “likely” that more...more

Womble Bond Dickinson

[Webinar] U.S. Anti-Corruption Enforcement in Latin America - October 22nd, 12:00 pm - 1:15 pm ET

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Latin America has been the focus of considerable attention by the Biden Administration and the DOJ. Despite strong ties based on trade, shared values and democratic traditions, Latin America is being tested with new and...more

Mintz

DOJ Reinforces Emphasis on Voluntary Self-Disclosure With Latest Updates to the Evaluation of Corporate Compliance Programs...

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On September 23, 2024, the Criminal Division of the United States Department of Justice (“DOJ” or the “Department”) revised its Evaluation of Corporate Compliance Programs guidance (the “ECCP”)....more

McDermott Will & Emery

Special Report: Preparing for CIRCIA’S Reporting Requirements and Avoiding Its Harsh Penalties

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The US Cybersecurity and Infrastructure Security Agency (CISA) recently published a Notice for Proposed Rulemaking intended to supplement the Cybersecurity Incident Reporting for Critical Infrastructure Act (CIRCIA). The...more

White & Case LLP

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

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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

A&O Shearman

Hong Kong Government considers changes to proposed critical infrastructure cybersecurity law

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The Security Bureau has completed its one-month consultation on its proposal in relation to the Protection of Critical Infrastructures (Computer Systems) Bill (the "Bill") and released the consultation report in its...more

Carlton Fields

Florida Appeals Court Decisions: Week of September 30-October 4, 2024

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U.S. Eleventh Circuit Court of Appeals - USA v. Hill - evidence, theft, false claim - Gilmore v. Ga DOC - en banc grant, vacating this qualified immunity decision - Johnson v. Terry - Bivens claims, rehearing...more

Dorsey & Whitney LLP

The Supreme Court Update - October 4, 2024

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Today, the Supreme Court of the United States granted certiorari in 15 cases: Waetzig v. Halliburton Energy Solutions, No. 23-971: This case concerns the intersection between Federal Rule of Civil Procedure 41, which...more

ArentFox Schiff

Eleventh Circuit Makes Wide-Ranging Ruling on Application of Co-Conspirator Hearsay Exception

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Last week, the Eleventh Circuit held that a conspiracy need not be unlawful to introduce co-conspirator statements under Federal Rule of Evidence 801(d)(2)(E), reversing the district court’s exclusion of certain statements....more

Kohrman Jackson & Krantz LLP

Title IX Challenges for Students with Autism Spectrum Disorder

Two major trends are simultaneously unfolding on college and university campuses around the country. One, growing numbers of students with autism spectrum disorder (ASD) are being accepted into higher education. Two, colleges...more

ArentFox Schiff

Investigations Newsletter: Florida Federal Judge Strikes Down FCA’s Qui Tam Provision as Unconstitutional

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Florida Federal Judge Strikes Down FCA’s Qui Tam Provision as Unconstitutional - On September 30, US District Judge Kathryn Kimball Mizelle of the Middle District of Florida held in a historic decision that the federal...more

King & Spalding

Department of Justice Continues to Focus on AI This Week

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On September 23, 2024, the U.S. Department of Justice (Department) announced that it had updated its guidance to prosecutors on how to evaluate the effectiveness of a corporation’s compliance program. The guidance, known as...more

The Volkov Law Group

Episode 339: Four Sanctions Cases Everyone Should Know

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How prepared is your organization to handle the evolving landscape of sanctions compliance? In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their...more

Mayer Brown

Senate Unanimously Holds Corporate Executive in Contempt of Congress for Failing to Comply with a Committee Subpoena

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On September 25, the US Senate held a corporate CEO in criminal contempt of Congress after he refused to comply with a subpoena to appear at a congressional hearing. Three days later, the company announced his resignation....more

Kilpatrick

Corporate Transparency Act Beneficial Ownership Report Filing Deadline for Companies Formed Before This Year is January 1, 2025 |...

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As we have previously reported, the federal Corporate Transparency Act (CTA) requires most privately held companies organized in the U.S. and foreign companies that register to do business in a U.S. state to file an online...more

Orrick, Herrington & Sutcliffe LLP

DOJ Updates Corporate Compliance Guidance, Takes Aim at AI, Emerging Technologies, and Data Analytics

Last week, the U.S. Department of Justice (DOJ) released an updated version of its Evaluation of Corporate Compliance Programs (ECCP) guidance, with key updates reinforcing the DOJ’s focus on the risks associated with...more

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