Earlier this month, the U.S. Attorney’s Office for the Southern District of New York (“S.D.N.Y”) announced a revised corporate self-disclosure policy designed to incentivize companies to cooperate in criminal investigations. The updated policy, which the S.D.N.Y. expects to publish soon, will offer carrots to corporations that disclose criminal conduct and agree to cooperate and remediate: … Continue Reading
On June 27, 2024, the Supreme Court issued its opinion in Securities Exchange Commission v. Jarkesy. The Court held that the Seventh Amendment entitles a defendant to a jury trial when the SEC seeks civil penalties for securities fraud, because these cases replicate common law fraud claims. S.E.C. v. Jarkesy, No. 22-859, slip op. at … Continue Reading
Last month in Percoco v. United States (U.S. May 11, 2023), the Supreme Court reversed the petitioner’s judgment of conviction for conspiracy to commit honest-services wire fraud for allegedly accepting $70,000 from a developer in return for asking a state agency to drop its labor peace agreement requirement. Joseph Percoco had previously served as Executive … Continue Reading
On November 28, 2022, the Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with Payward, Inc., known as Kraken (“Kraken”), a United States-based virtual currency exchange. Kraken agreed to pay $362,158.70 to resolve its potential civil liability for 826 apparent violations of the Iranian Transactions and Sanctions Regulations (“Apparent Violations”). The settlement amount … Continue Reading
On August 8, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned virtual currency mixer Tornado Cash for having laundered more than USD 7 billion worth of virtual currency since its founding in 2019. This includes over USD 455 million worth of stolen virtual currency associated with the Lazarus Group, … Continue Reading
