From Permits to Penalties: A Deep Dive Into Coastal Development Law
Podcast - FTC to Focus on Deceptive AI Claims: Compliance Management Strategies
Podcast - How Do You Define Success?
Episode 374 -- Justice Department Resumes FCPA Enforcement with New, Focused Guidance
Understanding the DOJ's Recent Corporate Enforcement Policy Changes
Workplace ICE Raids Are Surging—Here’s How Employers Can Prepare - #WorkforceWednesday® - Employment Law This Week®
False Claims Act Insights - Will Recent Leadership Changes Lead to FCA Enforcement Policy Changes?
FCPA Compliance Report: Recent DOJ Policy Announcements
Regulatory Rollback: Inside the CFPB’s FCRA Guidance Withdrawal — The Consumer Finance Podcast
Daily Compliance News for June 11, 2025. The A Bondi Too Far Edition
Cruising Through Change: The Auto-Finance Industry’s New Era Under Trump Unveiled — Moving the Metal: The Auto Finance Podcast
DOL Restructures: OFCCP on the Chopping Block as Opinion Letters Expand - #WorkforceWednesday® - Employment Law This Week®
Compliance Needs are Alive and Well: FTC's Recent Enforcement Activity
Compliance into the Weeds: Changes in FCPA Enforcement
Enforcement Priorities of the Second Trump Administration: The False Claims Act
Regulatory Rollback: Inside the CFPB's FCRA Guidance Withdrawal — FCRA Focus Podcast
Facial Recognition and Legal Boundaries: The Clearview AI Case Study — Regulatory Oversight Podcast
Daily Compliance News: June 10, 2025, The Ruinous Burdens Edition
Episode 372 -- DOJ Applies False Claims Act to Tariff and Trade Violations
Let’s say, once upon a time, you worked from home during the pandemic. If so, did you use a variety of communication methods (perhaps switching among different platforms, never sure which camera or microphone would be...more
On February 25, 2025, the U.S. Commodity Futures Trading Commission (CFTC) released an enforcement advisory regarding the impact of self-reporting, cooperation and remediation in enforcement cases (the “Enforcement...more
Yesterday, Acting CFTC Chairman Caroline Pham created a two-week window to bring “reasonable settlement offers” to the commission. Based on my conversations with her and others, I believe the CFTC is in “deal mode” and is...more
During her keynote address at the Futures Industry Association’s International Futures Industry Conference, BOCA50, CFTC Acting Chairman Caroline D. Pham announced a new effort to encourage market participants to resolve open...more
January is at least eight weeks – I’m certain of it. Now that it’s February we know who’s running the CFTC and its different Divisions, for the time being. Acting Chair Pham comes to her position with a long history of...more
The SEC's wave of enforcement actions concerning "off-channel" communications did not abate in 2024. In total, the SEC announced more than 70 firms agreed to pay more than a half-billion dollars combined to settle charges for...more
Organizations whose mantra is “We just never delete anything” (i.e., organizations simply retaining all information indefinitely) are now facing headwinds, especially when the information contains personal information. As our...more
SEC's and CFTC's Enforcement Actions Against Multiple Firms - In its continued pursuit of rooting out and penalizing broker-dealers and investment advisers for their failure to prevent unapproved communication methods, the...more
The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more
Regulators with the Federal Reserve and the Office of the Comptroller of the Currency (“OCC”) have fined JP Morgan Chase & Co. a combined total of $348.2 million over the bank’s failure to monitor client trading activities...more
The Department of Justice (DOJ) has updated their Evaluation of Corporate Compliance Programs policy with special attention paid to messaging platforms when detecting and investigating potential misconduct and law violations....more
Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more
The Commodity Futures Trading Commission (CFTC or Commission) released its enforcement results for fiscal year 2023 on November 7, 2023. The CFTC’s Division of Enforcement filed 96 enforcement actions in 2023 charging a range...more
In recent years, regulated industries, particularly broker dealer firms like Wells Fargo and Morgan Stanley, have faced increased scrutiny from regulatory bodies due to their lack of compliance in policing messaging apps. The...more
In an increasingly digital world, financial firms need to be mindful of the variety of electronic communication channels that their employees use for work. Even where firms require employees to use firm-managed email networks...more
The SEC and CFTC settlements with HSBC and Scotia Capital come after years of federal regulators’ and prosecutors’ steadily increasing scrutiny of off-channel communications. Anchoring these settlements are long-standing...more
Recent alleged recordkeeping failures resulted in aggregate fines in excess of $1.8 billion levied against 11 Wall Street financial institutions and many of their affiliated entities by the Securities and Exchange Commission...more
According to a recent press release from the Securities Exchange Commission (SEC), sixteen Wall Street firms were fined for widespread and longstanding failures by the organizations and their employees to maintain and...more
On September 21, 2022, U.S. District Judge George B. Daniels of the Southern District of New York dismissed with prejudice a putative securities class action against BELLUS Health, Inc. and certain of its officers....more
The SEC and CFTC recently charged 11 large financial institutions and their affiliates for failing to collect, monitor, and preserve communications over WhatsApp and other messaging services. These settlements follow a...more
Last week, the United States Securities and Exchange Commission (SEC) fined 16 Wall Street firms a total of $1.1 billion for recordkeeping violations based on the failure to maintain employees’ electronic communications, such...more
On September 27, the Commodity Futures Trading Commission (“CFTC”) issued orders to settle charges against 11 major U.S. and international financial institutions and their swap dealer (“SD”) and futures commission merchant...more
The SEC has, for many years, used broker-dealer and associated persons’ failure to create and maintain books and records as a basis for the imposition of serious penalties. In recent actions, it appears to be continuing—and...more
Last week, the Commodity Futures Trading Commission publicized a cascade of settlements of enforcement actions alleging breaches of laws and rules related to supervision, spoofing, reporting, and misappropriation of...more
An interdealer broker agreed to pay a fine of US $13 million to the Commodity Futures Trading Commission to resolve charges that it failed to supervise brokers on a swaps desk that allegedly made numerous false or misleading...more