On March 7, 2024, US Deputy Attorney General, Lisa O. Monaco announced the development of a new “DOJ-run whistleblower rewards program” during her speech at the American Bar Association’s 39th National Institute on White Collar Crime.[1] The announcement signals
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The UAE Exits FATF’s Grey List
The authors wish to thank Molly McKenna for her contributions to this post.
On February 23, 2024, the Financial Action Task Force (“FATF”) removed the United Arab Emirates (“UAE”) from its list of jurisdictions under increased monitoring (the “Grey List”).…
The SDNY Whistleblower Pilot Program Within the Framework of Corporate Criminal Enforcement
The United States Attorney’s Office for the Southern District of New York recently announced a policy—called the “SDNY Whistleblower Pilot Program”—that seeks to encourage individuals to voluntarily disclose financial crimes in which they themselves participated. First unveiled in January 2024…
Navigating Shifting Legal Landscapes: Implications of Deputy Attorney General Lisa Monaco’s Address to Oxford University on Artificial Intelligence
Deputy Attorney General Lisa Monaco’s (“Monaco”) recent remarks at Oxford University shed light on the evolving intersection of artificial intelligence (“AI”) and the criminal enforcement landscape and its profound implications for the United States Department of Justice and beyond. As…
Managing and Reporting Third-Party Cybersecurity Incidents Under the New SEC Cyber Risk Regulations
The rules on reporting cybersecurity risks and incidents pose many challenges for companies. Those challenges can be even more difficult when the cybersecurity incident affects third-party systems. With no exceptions for third-party cybersecurity incidents under the new cybersecurity reporting regulations,…
Webinar: The New Foreign Extortion Prevention Act – What It Means for US Companies
Please join us on Tuesday, January 30 for a discussion about “the most consequential anti-foreign-bribery law passed in almost 50 years”: the Foreign Extortion Prevention Act (FEPA).
FEPA allows the DOJ to prosecute foreign officials who demand or accept a…
Recent Changes to FATF’s “Grey List”; Could the UAE be Next Off the List?
Between October 25 and October 27, 2023, the Financial Action Task Force (“FATF”), an international policy-making and standard-setting body dedicated to combating money laundering and terrorist financing, held its third plenary meeting of the year (the “October Plenary”), at which…
FEPA: the New Tool in the DOJ’s Fight Against Corruption
On December 22, 2023, President Biden signed into law the Foreign Extortion Prevention Act (hereinafter “FEPA” or the “Act”) which was passed by the US Congress as part of the Fiscal Year 2024 National Defense Authorization Act. The Act aligns…
U.S. Sanctions Review: A Recap of OFAC’s Recent Enforcement Actions (Second Half 2023)
The second half of 2023 saw eight enforcement actions from the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). These actions reflect a range of penalties, industries, sanctions programs, conduct, and lessons learned. Below are some highlights from…
Noteworthy Trends in French White Collar Crime
France’s Sapin II Law was created in 2016 to address corporate corruption and implement antibribery measures. The legislation took effect in 2017, marking a significant shift in the country’s regulatory compliance landscape. The law, which tracks closely with similar laws…