On February 26, a long-running legal battle over the scope of the Foreign Corrupt Practices Act (“FCPA”) took another turn when a federal trial court judge ordered that former Alstom ...
The SEC Office of Compliance Inspections and Examinations (OCIE) recently published observations related to cybersecurity and operational resiliency practices observed in its examinations...
Last week, the House overwhelmingly passed legislation aimed at closing what lawmakers have called a “loophole” for insider trading—corporate insiders trading between the occurrence...
To assist legal and compliance officers of financial institutions, this memorandum summarizes key recent developments in criminal prosecutions and regulatory enforcement actions involving...
On December 30, 2019, the United States Court of Appeals for the Second Circuit affirmed the convictions of four individuals charged with disclosing and trading on nonpublic government in...
Assistant Attorney General Brian Benczkowski, the head of DOJ’s Criminal Division, recently gave a speech in which he clarified that DOJ will not automatically seek to impose agency lia...
The Department of Justice (“DOJ”) modified its Corporate Enforcement Policy to clarify what level of disclosure is expected from companies in the early stages of an investigation. In...
In October, President Trump signed two significant executive orders regarding fairness and transparency in federal agency guidance and enforcement. This visual memorandum provides an over...
The SEC’s Enforcement Division (the “Division”) released its annual report on November 6. The Division filed 7% more standalone cases in 2019 than it did in 2018, and financial sanc...
On Friday, November 1, 2019, the Supreme Court granted certiorari in Liu v. Securities and Exchange Commission, a case that challenges the SEC’s long-held position that it has authorit...
