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DOJ Sets New Focus and Priorities in Digital Assets Enforcement

On April 7, 2025, U.S. Deputy Attorney General Todd Blanche issued a memorandum titled “Ending Regulation by Prosecution” (the “Memorandum”), which set out clear and direct enforcement priorities for the U.S. Department of Justice (“DOJ”) relating to digital assets. The Memorandum clarifies that DOJ is not a digital assets regulator and that it will not … Continue Reading

UAE Enforcement Update: The FSRA and the DFSA Issue New AML-Related Fines

The UAE’s two financial free zones, established in the Emirates of Abu Dhabi and Dubai, possess their own civil and commercial legal frameworks, inclusive of court systems modeled closely on international standards and principles of common law and, importantly, autonomous financial services regulation.  In the Abu Dhabi Global Market (“ADGM”), which was established by UAE … Continue Reading

UK Sanctions Update: OFSI Releases Financial Services Threat Assessment – Part 2

Last month, the UK’s Office of Financial Sanctions Implementation’s (“OFSI”) published a Threat Assessment analyzing sanctions compliance involving UK financial services firms since February 2022, when Russia invaded Ukraine. In the first of our two-part article (available here), we summarized the six key areas of risk that OFSI identified in its Threat Assessment. In this … Continue Reading

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 suspend with immediate effect a number of sanctions and restrictive measures that had targeted key … Continue Reading

DOGE and a New Senate Caucus May Further Empower Inspectors General

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 Ernst (R-IA) and Chuck Grassley (R-IA) announced the launch of a bipartisan Inspector General Caucus. … Continue Reading

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 Bank, NatWest, Santander, Starling Bank, and TSB.[1] This new public-private partnership (“PPP”) was the largest … Continue Reading

EU Strengthens Sanctions Against Russia with 15th Package of Restrictive Measures

On December 16, 2024, the European Union (EU) adopted its 15th package of sanctions against Russia in response to its ongoing aggression toward Ukraine. The new measures target key sectors of Russia’s military-industrial complex, including the “shadow fleet” and companies that support this complex.  Our colleagues at The Trade Practitioner cover this significant development in … Continue Reading

OFAC Issues Additional Sanctions Guidance for the Maritime Shipping Industry

Failure to comply with the complex web of US sanctions laws and regulations carries significant risks both in terms of exposure to civil fines and penalties and reputational harm. To help maritime sector stakeholders navigate these regulations, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) has published scenario-based sanctions compliance guidance on … Continue Reading

Fast-Growing UK Challenger Bank Fined £29m for Insufficient Sanctions and Financial Crime Controls

On September 27, 2024, the Financial Conduct Authority (“FCA”), which is a financial regulatory body in the UK that regulates firms providing financial services to consumers, fined a UK Challenger Bank (the “Bank”) £29 million due to significant failings in its financial sanctions compliance and anti-money laundering systems and controls. The FCA’s Summary of Reasons … Continue Reading

New 10-Year Statute of Limitations for U.S. Sanctions Violations

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

Increased Corporate Transparency in the Cayman Islands

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

DOJ Promises Whistleblower Rewards Pilot Program and Adds AI Risk to Its Evaluation of Corporation Compliance Programs

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

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 the Chief Operating Officer of the Department of Justice, Monaco’s insights underscore the critical importance … Continue Reading

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 it made important updates to its list of jurisdictions under increased monitoring, often externally referred … Continue Reading

FinCEN Penalizes Puerto Rican Bank for BSA Violations in First Enforcement Action Involving the “Gap Rule”

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

VARA’s Strict Application of its Virtual Assets and Related Activities Regulations 2023

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

FCA Investigates Bank Account Closures, Including for PEP Customers

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

Live Event:  Avoiding Litigation and Navigating Regulatory Challenges Amid Growing Privacy, Cybersecurity and Artificial Intelligence Scrutiny

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

DOJ Announces New Compensation Incentives and Clawbacks Pilot Program

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

New DOJ/Commerce ‘Disruptive Technology Strike Force’

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

Compliance Risks for Remote and Hybrid Working Models

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

Series: Remedies available to companies harmed by industrial espionage

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

Series: Overview of Ways to Legally and Practically Protect Your Company from Industrial Espionage

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

Does DOJ Approve Of Your Messaging App?

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
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