Multi-defendant criminal investigations present a classic prisoner’s dilemma. The parties would benefit from cooperating with one another but are incented to become adversaries, most often due to a lack of information sharing and resultant lack of trust and transparency. Fortunately,
Global Investigations & Compliance Review
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DOJ’S False Claims Act Based Civil Cyber-Fraud Initiative in 2024
The start of a new year presents an opportune time to reflect on the past. We have been tracking and reporting on the U.S. Department of Justice (“DOJ”)’s Civil Cyber-Fraud Initiative (“CCF Initiative”), which former U.S. Deputy Attorney General Lisa…
The EU suspends certain Sanctions on Syria to support Economic Stabilization, Political Transition, and Reconstruction
To encourage democratic development and achieve a peaceful and inclusive political transition, and to aid the swift reconstruction and economic recovery of the country and facilitate its eventual reincorporation into the global financial system, the European Council decided yesterday to…
Trump Pauses FCPA Enforcement and Resets Priorities
On February 10, 2025, President Donald Trump issued an executive order titled, “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security” (“FCPA EO”) that directs the Department of Justice (“DOJ”) to pause enforcement of…
Update on the Proposed Amendments to the Foreign Agents Registration Act Regulations
By Clark Ervin
On her very first day in office, Attorney General Pam Bondi issued a sweeping memorandum laying out what the Department of Justice’s (DOJ) enforcement priorities will be going forward under her leadership. It seems that the Foreign Agents Registration Act…
UK Sanctions Update: New OFSI Reporting Requirements for High Value Dealers and Art Market Participants
Late in 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), the agency within His Majesty’s Treasury that is charged with the implementation of financial sanctions in the UK, introduced new sanction measures aimed generally at augmenting the operation and…
To Disclose or Not to Disclose (and how much) – That is the Question
The decision-making process involved in disclosing a cyber incident is a nuanced and delicate dance. Companies need to consider a myriad of factors, including when to disclose and how much detail to disclose to employees, customers, or regulators, such as…
DOGE and a New Senate Caucus May Further Empower Inspectors General
By Clark Ervin
In the flurry of developments last week in the run-up to the inauguration, it was easy to overlook one that could have significant and positive impact by making government more effective, efficient, and economical.
On January 17, 2025, Senators Joni…
Time is of the Essence to Implement New ADGM Whistleblower Protection Regulations
In 2024, the Abu Dhabi Global Market (“ADGM”) further enhanced transparency, accountability, and market integrity within the financial freezone by introducing the Whistleblower Protection Regulations 2024 (the “Regulations”). In brief, those Regulations require certain entities registered or licensed to operate…
Promising Results from Groundbreaking FinCrime Data Sharing Project Between Seven UK Banks and the National Crime Agency
In 2024, the National Crime Agency (the “NCA”), which is the UK’s lead agency against organized crime; human, weapon and drug trafficking; cybercrime; and economic crime, announced its “groundbreaking” data sharing partnership with seven UK banks, namely Barclays, Lloyds, Metro…