FinCEN recently issued the much-anticipated national AML/CFT priorities and announced its intention to implement a no-action letter process to complement to its current regulatory guidanc...
The SEC filed an enforcement action involving a public company’s cybersecurity disclosure. The action highlights the need for executives responsible for SEC reporting to be informed pro...
The House of Representatives has passed a bill on a bipartisan basis that would be the first statute directly banning insider trading in the securities markets. The bill largely would pr...
The Securities and Exchange Commission’s recent case against a registered broker-dealer for not filing Suspicious Activity Reports (SARs) reinforces the SEC’s focus on anti-money laun...
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 th...
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 Tran...
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. T...
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 requi...
