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1 month ago | 
lexology.com | Matthew Abbott |Jarryd E. Anderson |Jessica Carey |Andrew Fishman |Roberto González |Brad S. Karp | +1 more
For additional guidance on the Trump administration’s executive orders, visit our Regulatory/Administrative Tracker. To download a compendium of our recent analysis, click here.
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2 months ago | 
news.bloomberglaw.com | Loretta Lynch |John Carlin |Mark F. Mendelsohn
The Bottom Line for Companies Look at compliance programs, including “know-your-customer” and third-party risk management practices, to ensure that they are addressing cartel and transnational criminal organization risks. Counterparty risk management processes, including due diligence, engagement, and monitoring practices, may need adjustments. Don’t assume DOJ will drop existing investigations that are outside these new priorities. Attorney General Pamela Bondi’s 14 directives issued Feb.
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Oct 15, 2024 | 
lexology.com | L. Atkinson |Jessica Carey |John Carlin |Roberto González |Brad S. Karp |Loretta Lynch | +7 more
On October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued guidance to financial institutions on “best practices” for compliance with the Export Administration Regulations (“EAR”), including General Prohibition 10.[1] The Guidance appears to mark the first time that BIS has formally indicated that U.S. and non-U.S. financial institutions could be the subject of enforcement actions by BIS for violating the export control regulations directly.
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Oct 2, 2024 | 
lexology.com | L. Atkinson |Jessica Carey |John Carlin |Roberto González |Brad S. Karp |Loretta Lynch | +7 more
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) recently issued new regulations that will have significant impacts on the compliance obligations of persons subject to U.S. jurisdiction, and particularly financial institutions. First, OFAC issued a Final Rule that describes the types of non-public “tailored actions” it can take.
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Sep 18, 2024 | 
newsbreak.com | Loretta Lynch
Caught in processes and facilities designed and built around the needs of men, women struggle to overcome a unique set of obstacles throughout their experience with the criminal justice system. Most justice-involved women come from backgrounds of poverty and trauma, and they are more likely than men to be victims of physical and sexual abuse , suffer severe substance use and mental health issues, and to have experienced homelessness in the year prior to incarceration.
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Aug 7, 2024 | 
lexology.com | L. Atkinson |H. Christopher Boehning |Walter Brown |Jessica Carey |John Carlin |Roberto Finzi | +13 more
On August 1, 2024, the U.S. Department of Justice’s Criminal Division (“DOJ” or “Department”) launched a new Corporate Whistleblower Awards Pilot Program (the “Whistleblower Pilot Program” or the “Pilot Program”).[1]Under the Pilot Program, eligible whistleblowers who provide the Criminal Division with original and truthful information about certain types of corporate misconduct are eligible to receive a portion of a criminal or civil forfeiture exceeding $1 million.
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Apr 20, 2024 | 
sfchronicle.com | Loretta Lynch
California now holds the ignominious prize for the highest electricity rates in the nation, except Hawaii. How did we get into this predicament? Because the California Public Utilities Commission — the five-member agency appointed by Gov. Gavin Newsom that regulates the prices, service and reliability of private energy utilities — has failed to do its job.
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Feb 21, 2024 | 
lexology.com | H. Christopher Boehning |Jessica Carey |John Carlin |David C. Fein |Michael E. Gertzman |Roberto González | +4 more
On February 13, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a proposed rule aimed at “keep[ing] criminals and foreign adversaries from exploiting the U.S. financial system and assets through investment advisers” (the “Proposed Rule”).[1] The Proposed Rule would require SEC-registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) (together, “Covered Investment Advisers”) to establish anti-money laundering/countering the...
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Feb 15, 2024 | 
lexology.com | Walter Brown |Susanna M. Buergel |Jessica Carey |John Carlin |Andrew J. Ehrlich |Roberto Finzi | +8 more
During the third year of Chair Gary Gensler’s and Director of Enforcement Gurbir Grewal’s leadership, several key enforcement priorities for the SEC impacted and will likely continue to impact businesses across a range of sectors for years to come. In this year in review, we highlight important takeaways for business leaders and in-house counsel from the Division’s activities in 2023, and what these activities suggest for the Division’s priorities for the year ahead.
