Department of Justice Guidance on Companies’ Claim of Inability to Pay Criminal Fines

By Nicholas B. McGrath & Brenna R. McLean on October 17, 2019

The Department of Justice Criminal Division has clarified its policy on the Department’s assessment of a company’s claim that it cannot afford to pay a criminal fine in a memorandum issued on October 8, 2019. Criminal Division department head Brian Benczkowski had previewed the memorandum during a speech in September. While the DOJ already permitted corporate defendants to seek reduction of criminal fines, the Benczkowski memo sets forth more specific guidelines on the factors that…

Hanzo Blog

Meet Team Hanzo: Kristin Oberhaus — Drumming up Enthusiasm For Everything from Slack Legal Hold to the Ohio State Buckeyes

By Sarena Regazzoni on October 15, 2019

Getting to know Kristin is like making a friend in college. She’s a great partner in business who analyzes problems and brings thoughtful reflection to every challenge. Yet, in the same breath she also brings unwavering enthusiasm to her team and the customers she supports. What is your role at Hanzo? My role at Hanzo is that of Business Analyst. In this role, my purpose in life is to take the strategic vision of…

Money Laundering Watch

Joint Statement on Digital Assets Highlights AML Regulatory Overlap

By Peter D. Hardy on October 13, 2019

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 Commission (“CFTC”), and the Securities and Exchange Commission (“SEC”) issued a “Joint Statement on Acitivites Involving Digital Assets” in order to “remind persons engaged in activities involving digital assets of their anti-money laundering and countering the financing of terrorism (AML/CFT) obligations…

Government Contracts Legal Forum

Legal Careers in Cybersecurity, Privacy & Information Law Event

By Kate M. Growley, CIPP/G, CIPP/US, Michael G. Gruden, CIPP/G & Allegra Flamm on October 11, 2019

On October 24, 2019, Crowell & Moring in conjunction with the American Bar Association will be hosting the sixth annual Legal Careers in Cybersecurity, Privacy & Information Law networking and discussion event. This event offers law students and new lawyers the opportunity to learn how to meld law, policy, and technology, and better navigate the unprecedented legal challenges emerging from the cyber, homeland, and privacy frontiers. Attendees will hear from an exceptional cast of experienced…

Money Laundering Watch

The OCC Releases Fiscal Year 2020 Bank Supervision Operation Plan

By Gretchen L. Gurstelle on October 9, 2019

On October 1st, the Office of the Comptroller of the Currency (OCC) published the Fiscal Year 2020 Bank Supervision Operating Plan (“FY 2020 Plan”). The FY 2020 Plan sets forth the OCC’s supervision priorities and objectives for the fiscal year beginning October 1, 2019 and ending September 30, 2020. The supervision priorities set forth align with the the OCC’s Strategic Plan, Fiscal Years 2019-2023. The FY 2020 Plan facilitates the development of supervisory strategies…

Franchise Law Update

Time to Exhale . . . CAUTIOUSLY: Ninth Circuit has good news for franchisors

By Natalma M. McKnew on October 7, 2019

I admit I was among the scores of franchise lawyers whose blood pressure skyrocketed with passage of California’s AB 5. If a Franchise Agreement establishes an independent contractor relationship between franchisor and franchisee, will the A-B-C test render the franchisor the employer of the franchisee? And if that’s the case, how is the franchisor NOT the employer of the franchisee’s employees? Absent a statutory exemption for franchises, AB 5 invited those dark queries. I’m…

Money Laundering Watch

Anti-Terrorism Act Liability Requires More than Mere Failures of Customer Due Diligence

By Priya Roy on October 4, 2019

On September 25, 2019, the Southern District of New York dismissed a complaint brought by victims of rocket attacks in Israel perpetrated in 2006 by Hizbollah, operating in Lebanon. Kaplan v. Lebanese Canadian Bank, SAL, Civ. No. 08 Civ. 7253, 2019 U.S. Dist. LEXIS 162505 (S.D.N.Y. Sept. 20, 2019). The Complaint was brought under the Anti-Terrorism Act, 18 USC 2333 (“ATA”). In it, the Plaintiffs alleged that the Lebanese Canadian Bank, SAL (“LCB”) provided…

Novare Law Group Blog

[Action required] Your RSS.app Trial has Expired – Fri Oct 04 2019

By Ashley Schmolinger on October 3, 2019

I tried several RSS feed generators and the one that worked best, aside from being the simplest, was RSS.app. It’s great how useful the tool can be for somebody that doesn’t know how to code. Kiril Gantchev CEO ofST6 I’ve long wanted an app that generates RSS feeds from social media sites, and while there are other options that do it (IFTTT, Zapier, etc.), this is the first one that is dead simple, and…

Hanzo Blog

There’s No One “Right” Version of an Emoji: A Conversation With Eric Goldman

By The Profiles of Excellence Series on September 30, 2019

Eric Goldman, an Internet law professor, gives us an overview of emoji law, including the pros—more precise and nuanced communication—and the cons—more ambiguity and room for misinterpretation. Eric Goldman is a Professor at Santa Clara University School of Law, where he teaches and publishes on Internet law, intellectual property, and advertising and marketing law. He also serves as co-director of the High Tech Law Institute and Supervisor of the Privacy Law Certificate and blogs—quite prolifically—on…

Hanzo Blog