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Troutman Pepper

DOJ Updates Guidance on Corporate Compliance Programs With Focus on AI

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On September 23, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced that the U.S. Department of Justice (DOJ) updated its guidance on the Evaluation of Corporate Compliance Programs (ECCP). The DOJ’s...more

Cooley LLP

DOJ Focuses on AI, Emerging Tech in Newly Issued Guidance Updates for Evaluating Corporate Compliance Programs

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On September 23, 2024, the Criminal Division of the US Department of Justice (DOJ) issued an updated Evaluation of Corporate Compliance Programs (ECCP). The updated ECCP emphasizes that companies should address risks...more

Alston & Bird

DOJ Unseals Indictment of Evil Corp Member, While OFAC Announces New Evil Corp Sanctions

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On October 1, 2024, the Department of Justice (“DOJ”) unsealed an indictment against Aleksandr Viktorovich Ryzhenkov (Александр Викторович Рыженков), a member of the ransomware group Evil Corp.  The indictment charges...more

Locke Lord LLP

FUNDamentals: Navigating FinCEN’s ‎New AML Regulations for Investment ‎Advisers

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On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Rule”) that amends the definition of “financial institution” under the Bank Secrecy Act...more

Orrick, Herrington & Sutcliffe LLP

California amends its criminal code to include mortgage fraud and consumer protections

On September 24, the Governor of California approved AB 3108 (the “Act”), amending the Financial Code and Penal Code to address mortgage fraud and consumer protections. The Act prohibits knowingly filing any document with a...more

Society of Corporate Compliance and Ethics...

Public-Private Partnerships to Stem Corruption

Governments don’t only want to prosecute companies for paying bribes. Increasingly, they are looking for companies to join with them to reduce the global challenge of corruption. To learn more we spoke with Shruti Shah,...more

Littler

San Diego County Adds a New Layer to California’s Complex Web of Laws Regulating the Use of Criminal Records in the Hiring Process

Littler on

California state law already saddles private sector employers with significant obligations to job applicants with a criminal record. Various local laws layer on top of these obligations to make compliance even more...more

King & Spalding

DOJ Releases Updated Version of Evaluation of Corporate Compliance Programs Guidelines

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On September 23, 2024, DOJ announced updates to its Evaluation of Corporate Compliance Programs guidelines (Guidance). The updates are the latest in a series of updates (including in 2019, 2020, and 2023) since DOJ first...more

Rivkin Radler LLP

Lab Owner Pleads Guilty to COVID-19 Testing Fraud Scheme

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On October 1, the U.S. Attorney’s Office for the Northern District of Illinois announced that Zishan Alvi, the owner of a Chicago laboratory, pleaded guilty to one count of wire fraud for his role in a COVID-19 testing fraud...more

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

Wiley Rein LLP on

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

Cozen O'Connor on

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...

Mintz on

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

McDermott Will & Emery on

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

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