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OFAC Releases Sanctions Compliance Guidance for the Virtual Currency Industry

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury recently published sanctions compliance guidance for the virtual currency industry (the Guidance).  The move was long anticipated, given the rapid industry growth and limited regulator guidance in this space.  The Guidance provides an overview of OFAC sanctions requirements and procedures, including … Continue Reading

FinCEN Director Blanco Encourages Increased Communication During Global Pandemic

In remarks to the Association of Certified Anti-Money Laundering Specialists (“ACAMS”), Kenneth A. Blanco, the Director of the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), covered a number of high-priority topics, including FinCEN’s response to the pandemic, the latest COVID-19 related fraud schemes, emerging cyber threats, virtual currency issues, and important regulatory updates.  A theme … Continue Reading

SEC Approves Changes to Its Whistleblower Program

This week, in a 3-2 vote, the U.S. Securities and Exchange Commission (“SEC” or the “Commission”) approved significant changes to the rules governing its whistleblower program.  The program, established by the Dodd-Frank Act in 2011, incentivizes those with information about possible securities law violations to report to the SEC.  If the tipster provides “high-quality original … Continue Reading

Provider Tips For Telehealth Compliance

Although the rapid shift to telehealth is a boon to providers and patients, the federal government has issued specific guidance that providers need to follow.  See tips for compliance provided by David Maria, a former federal prosecutor and member of the Department of Justice Medicare Fraud Strike Force, and Trevor Garmey, a Senior Associate with … Continue Reading

DOJ Civil Division Highlights False Claims Act Priorities for 2020

Joseph “Jody” Hunt, Assistant Attorney General for the Civil Division, provided a glimpse of current civil enforcement priorities of the Department of Justice (DOJ).  Speaking at the Federal Bar Association’s annual Qui Tam Conference on February 27, 2020, Hunt pledged that DOJ would pursue qui tam cases involving nursing homes, Medicare Advantage plans, and electronic … Continue Reading

Market Integrity Amid COVID-19 Pandemic

While the world and markets are reeling, dealing with and adapting to the COVID-19 pandemic, the Securities & Exchange Commission’s (SEC’s) Division of Enforcement wants companies and individuals to know that it’s business as usual at the SEC. This week, Stephanie Avakian and Steven Peikin, Co-Directors of the SEC’s Enforcement Division, issued a statement regarding … Continue Reading

Inspector General Supports Whistleblowers

In his semi-annual report to Congress, Michael K. Atkinson, the intelligence community’s inspector general, expressed “hope that recent events will not have a chilling effect on the willingness of individuals within the Intelligence Community to continue to shed light on suspected fraud, waste, abuse, or malfeasance in an authorized manner.” In an article published in Corporate … Continue Reading

How to Survive a Congressional Investigation

Learn from the experts how you and your organization can navigate a congressional investigation from start to finish.  Our webinar on Wednesday, December 18, will help you understand the basics of a congressional investigation and what is required to avoid irreparable harm to business or reputation. Margaret Daum, partner and former Staff Director at the US Senate Committee … Continue Reading

Congress Seeks Reform of Red Notice Abuse

A Red Notice allows for detention of an international fugitive. But the practice has been criticized for abuse. In response, a bipartisan group of Congresspersons have introduced the Transnational Repression Accountability and Prevention Act (“the TRAP Act”). This reform legislation, if enacted, will affect politically-motivated Red Notices and enforcement of them around the world.… Continue Reading

Can Artificial Intelligence Be Used as a Tool to Help Ukraine Fight Corruption?

With day four of public hearings in the President Trump’s impeachment proceedings, Ukraine is on everyone’s mind. In his public testimony on November 19, 2019, Lieutenant Colonel Vindman mentioned several of Ukraine’s anti-corruption efforts, including the establishment of High Anti-Corruption Court.  For the most part, however, consistent with the origin of the impeachment inquiry, the … Continue Reading

New Antitrust Strike Force Focuses on Government Contracts

A new strike force of federal and state investigators is targeting antitrust violations in government procurement. The strike force consists of investigators from a variety of agencies who will receive special training in detecting and prosecuting antitrust agreements. The strike force seeks to increase both criminal and civil enforcement actions.… Continue Reading

Australia Plans to Join U.S. and U.K. in the CLOUD Act

Following its agreement with the United Kingdom, the United States announces formal negotiations are underway with Australia about joining the CLOUD Act. Although also a bi-lateral negotiation, the U.S. talks with Australia strike a more practical tone than those with the U.K.… Continue Reading

U.S. and U.K. Ease Data Collection Across Borders

Saying it will accelerate complex investigations, the United States and the United Kingdom proposed an historic data exchange agreement. In future, each government will be able to obtain electronic data directly from technology companies in the other country. The governments also say this first of its kind agreement will protect privacy and enhance civil liberties.… Continue Reading

Does D&O Insurance Cover Criminal Charges?

Sometimes an investigation of corporate conduct results in criminal charges. Will an insurance policy protecting Directors and Officers (D&O) pay the costs of those criminal charges? Larry Schiffer reports on a recent decision from the Eleventh Circuit interpreting Florida law. Larry’s post (here) reveals the importance of knowing the scope of your policy.  … Continue Reading

Antitrust Division Acts to Reward Corporate Compliance

The Antitrust Division of the Department of Justice (“Division”) now considers a company’s compliance program at the charging and sentencing stages in a criminal antitrust investigation.  The Division incorporated these changes into the Justice Manual. The Division also published a guide for evaluating compliance programs under this new approach.… Continue Reading
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