On April 24, 2024, President Biden signed into law H.R. 815[1], an emergency supplemental appropriations law, that provides $95.3 billion in military aid to U.S. allies and requires the divestiture of certain social media applications. While much of the discussion surrounding the new law focuses on the emergency foreign aid funding for Ukraine, Israel, and … Continue Reading
The Cayman Islands, a British overseas territory, has long been recognized as one of the world’s leading providers of institutionally focused financial services and a preferred destination for the structuring and domiciling of sophisticated and specialized financial services products, particularly investment funds. However, for a number of reasons, the inherent risks to the Cayman Islands’ … Continue Reading
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 “a 90-day sprint to develop and implement a pilot program, with a formal start date later this … Continue Reading
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 the Chief Operating Officer of the Department of Justice, Monaco’s insights underscore the critical importance … Continue Reading
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 it made important updates to its list of jurisdictions under increased monitoring, often externally referred … Continue Reading
On September 15, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced a $15 million civil money penalty against a Puerto Rican International Banking Entity (“IBE”), Bancrédito International Bank and Trust Corporation (“Bancrédito” or “the Bank”). The public consent order details the Bank’s multiple violations of the Bank Secrecy Act (“BSA”), … Continue Reading
The United Arab Emirates (“UAE”) has long been at the forefront of embracing technological and financial innovation. For example, Dubai has emerged as a global hub for virtual assets (“VAs”) and cryptocurrencies. Earlier this year, the Dubai Virtual Assets Regulatory Authority (“VARA”) adopted its first Virtual Assets and Related Activities Regulations 2023 (the “Regulations”), along … Continue Reading
Following concerns raised by the government of the United Kingdom (“UK”) about freedom of expression and the provision of banking services, the UK’s financial watch dog, the Financial Conduct Authority (“FCA”), recently commenced an investigation into bank account closures. This action follows in the wake of recent reports of banks allegedly closing customer accounts based … Continue Reading
Join subject matter experts across policy, litigation, and regulation for an engaging discussion around privacy, cybersecurity, and AI. This live event will be in our Washington DC office and will include perspectives from in-house leaders, a former FBI agent, an incident response forensic expert, world-class public policy experts, and our privacy and cybersecurity professionals. The … Continue Reading
As we recently discussed, the Department of Justice released new guidance covering a multitude of topics, including employees’ use of personal electronic devices and third-party messaging platforms, financial compensation incentives and clawbacks. At the American Bar Association’s 38th Annual National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced the launch of the … Continue Reading
Last week, the U.S. Department of Justice (DOJ) and U.S. Department of Commerce (Commerce) announced the creation of a “Disruptive Technology Strike Force.” The strike force will be co-led by DOJ’s National Security Division and Commerce’s Bureau of Industry and Security, with support from 14 U.S. Attorneys’ Offices in 12 major metropolitan areas across the … Continue Reading
With the cold and flu season underway and COVID-19 still ever-present, it is a good time to take stock of the potential risks that come with working remotely. Following the lifting of pandemic restrictions allowing offices to open back up, many companies continued to offer work from home or hybrid arrangements. It is important for … Continue Reading
The authors would like to thank Thomas Fogarty and Anya Bharat Ram for their contributions to this post. Section 1832 of the Economic Espionage Act of 1996 (the “Act”) criminalizes the theft of trade secrets “intended for use in interstate or foreign commerce, to the economic benefit of anyone other than the owner.” 18 U.S.C. § 1832(a). … Continue Reading
As we discussed in a previous article, companies can be at risk from internal and external sources of industrial espionage, in an attempt to gain an unfair competitive advantage or disrupt operations. Legal Protections Owners of a trade secret have a federal cause of action against an individual or company that misappropriates their trade secret … Continue Reading
The Department of Justice released new Enforcement Policy for the Foreign Corrupt Practices Act (FCPA). The revisions include a new provision that many believe impairs the use of instant messaging software and other third-party messaging apps by employees. In order to receive a declination and full credit for cooperating with investigators under the Enforcement Policy, U.S. companies … Continue Reading
Part I: Background During the era when the Sony Walkman birthed the personal audio revolution, Nintendo Entertainment Systems appeared on American shores, and Gordon Gekko made wireless phone calls on his chunky mobile phone, the 99th United States Congress passed the Stored Communications Act (SCA). Enacted in 1986, the SCA governs U.S. authority to compel … Continue Reading
