Episode 335 -- The New DOJ Whistleblower Program
Navigating Emerging Privacy Issues in Financial Services — The Consumer Finance Podcast
Implications of the SEC Cybersecurity Disclosure Rule
Corruption, Crime and Compliance: SEC Suffers Dismissal of Claims in Solarwinds Securities Fraud Case
Episode 334 -- District Court Dismisses Bulk of SEC Claims Against Solarwinds
The Woody Report: The Solar Winds Dismissal
In That Case: Securities and Exchange Commission v. Jarkesy
Corruption, Crime and Compliance: Deep Dive into The SEC’s Settlement with R&R Donnelly on Cybersecurity Controls
Episode 332 -- Deep Dive into SEC’s Internal Controls and Cybersecurity Settlement with R&R Donnelly
The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State
DE Under 3: OFCCP Must Shut Down its Administrative Court Prosecutions as a Result of SCOTUS’ SEC Jury Trial Case Decision
Dogecoin’s Day in Court
Unpacking the Lummis-Gillibrand Payment Stablecoin Act: Implications for the Digital Asset Industry — The Crypto Exchange Podcast
Podcast: Is Cryptocurrency a Security (like an orange grove)?
Navigating the Regulatory Waters: The SEC's Wells Notice to Uniswap and its Impact on DeFi — The Crypto Exchange Podcast
Will Resiliency Carry the Digital Asset Sector Through 2024: Federal Legislative Developments and OFAC Consent Orders — The Crypto Exchange Podcast
Compliance into the Weeds: The WACKO Enforcement Action Involving BF Borgers
Meeting the Proposed SEC Climate Disclosure Requirements
Understanding the Whistleblower Pilot Program in the Southern District of New York
2 Gurus Talk Compliance: Episode 26 – The Compliance Week Wrap Up Edition
As an evolving area of commercial disputes in the Cayman Islands, global enforcement trends provide us with valuable insight into the types of regulatory proceedings on the horizon for offshore jurisdictions. In this first...more
The Development: On August 1, 2024, the Department of Justice's ("DOJ") Criminal Division announced its Corporate Whistleblower Awards Pilot Program ("Pilot Program"), designed to reward whistleblowers who report information...more
Earlier this year, as described in a previous client alert, the Department of Justice (“DOJ”) Criminal Division announced a landmark pilot program to pay monetary awards to whistleblowers (the “Program”). At that time, Deputy...more
On August 1, 2024, the US Department of Justice (“DOJ” or “Department”) released highly anticipated details of its new Corporate Whistleblower Awards Pilot Program (“Pilot Program”), with Principal Deputy Assistant Attorney...more
For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more
The Financial Crimes Enforcement Network (FinCEN), the Commodity Futures Trading Commission (CFTC), and the SEC have adopted or are proposing substantial increases in regulation of industry participants, primarily investment...more
On April 22, 2024, the Acting Assistant Attorney General for the Department of Justice (“DOJ”) Criminal Division (“Acting AAG”) Nicole M. Argentieri offered commentary in a blog post regarding the Criminal Division’s newest...more
It was a busy year for enforcement activity in the cyber, crypto, SPAC, and whistleblower spaces, with several pending actions that will likely have wide-ranging implications in 2024. We are also awaiting a ruling from the...more
November 16, 2023- The Financial Crimes Enforcement Network (FinCEN) has updated its Beneficial Ownership Information FAQs to include new questions about the reporting process, reporting companies, beneficial owners,...more
On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the Digital Asset Anti-Money Laundering Act (the “Act”), legislation aimed at closing...more
U.S. House Financial Services Committee Chairman Patrick McHenry (NC-10) sent a letter to Secretary of the Treasury Janet Yellen regarding Treasury's rumored Executive Order on outbound investment to China....more
On December 14, Senators Elizabeth Warren (D-Mass.) and Roger Marshall (R-Kan.) introduced in the U.S. Senate a new bipartisan bill, titled "Digital Asset Anti-Money Laundering Act of 2022" (the “Bill”), intended to curb the...more
With the enduring popularity of certain NFTs and the promise of their use in the Metaverse and beyond, the hype around the new technology has been accompanied by rising concerns over NFTs being the centerpiece of traditional...more
Major Developments- Federal Reserve Board- Federal Reserve Board releases results of annual bank stress test- June 23, 2022- The Federal Reserve Board released the results of its annual bank stress test....more
The G7 Finance Ministers and Central Bank Governors issued a communique on the results of their May 18-20 Meeting in Petersburg, Germany....more
The U.S. Senate Committee on Banking, Housing, and Urban Affairs held a hearing on the following nominations: The Honorable Michael S. Barr, of Michigan, to be a Member and Vice Chairman for Supervision of the Board of...more
The U.S. Securities and Exchange Commission (SEC) recently awarded approximately $36 million to a whistleblower who was culpable in the wrongful conduct and delayed reporting information to the agency for five years. The...more
This year, regulators, supported by a slate of new legislation, have focused more of their efforts on AML violations and compliance deficiencies than ever before. As we have written about in the "AML Enforcement Continues to...more
FinCEN issues implementing regulations that “ensure” compliance with the BSA. FinCEN delegates its examination authority to federal agencies. These federal agencies are the “Federal Functional Regulators” who supervise...more
DOJ’s Cyber Digital Task Force’s report, “Cryptocurrency: An Enforcement Framework,” provides a comprehensive on the growing partnerships between DOJ and other offices within the executive branch....more
Earlier this month, the Department of Justice (“DOJ”), through its Cyber Digital Task Force (hereinafter the “Task Force”), published its 83-page crypto guidance report titled “Cryptocurrency: An Enforcement Framework.”...more
- Market participants should review and assess their compliance procedures to prevent and detect insider trading risks associated with COVID-19. - Companies should increase their vigilance regarding cybersecurity threats...more
A Director of Enforcement at the Financial Conduct Authority (FCA) has set out some of the key challenges the regulator expects in its new role as AML/CTF (anti-money laundering/counter terrorist financing) supervisor for...more
Strikeout for Bitcoin ETF - Another ETF bites the dust. On February 26th the SEC rejected the application of NYSE Acre for the approval of an exchange traded fund sponsored by the New York firm of Wilshire Phoenix to...more
Leaders of FinCEN, CFTC and SEC Attempt an Intricate Dance of Competing Oversight of Virtual Currency - On October 11, the leaders of the Financial Crimes Enforcement Network (“FinCEN”), the Commodity Futures Trading...more