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The U.S. federal banking agencies have issued an interagency statement addressing industry questions on model risk management and AML compliance. Specifically, the statement clarifies the…
The Financial Crimes Enforcement Network of the U.S. Department of the Treasury has begun a rulemaking to implement the beneficial ownership reporting provisions of the new Corporate…
Parties considering whether to settle an SEC enforcement investigation or criminal proceeding have a reasonable expectation that they will know the likely consequences of a settlement. …
In a recently issued administrative order, the SEC implicitly acknowledged that the limiting principles for disgorgement that the Supreme Court outlined in Liu v. Securities and Exchange…
Davis Polk is pleased to present its DOJ and SEC FCPA Resolution Tracker. The tracker details key characteristics of corporate and individual FCPA resolutions and is available through the…
On January 11, 2021, the Supreme Court vacated the Second Circuit’s controversial decision in United States v. Blaszczak, which held that proof of a benefit to the tipper is not a required…
Congress overrode the President’s Veto of the National Defense Authorization Act. Among other things, the new law expands to 10 years the time for the SEC to bring disgorgement claims in…
The Anti-Money Laundering Act of 2020 implements the most extensive revisions to anti-money laundering law since the USA PATRIOT Act of 2001. The changes will affect both traditional…
This memo summarizes the amendments to the Federal Reserve’s emergency powers, the Paycheck Protection Program, other support for small businesses, and certain other provisions included in…
On December 15, 2020, the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation issued a notice of proposed rulemaking that…