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DOJ and SEC Cross-Border Priorities Require Increased Vigilance for Multinational Organizations and Their Advisors Image

DOJ and SEC Cross-Border Priorities Require Increased Vigilance for Multinational Organizations and Their Advisors

Jonathan New & Patrick Campbell & Alaina Ciccone

Both federal agencies are aligning their enforcement priorities with the Administration’s foreign policy goals, signaling heightened scrutiny of cross-border misconduct and increased compliance expectations for multinational organizations and their auditors and advisers.

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The Criminal Tariff Enforcement Wave Is Coming Image

The Criminal Tariff Enforcement Wave Is Coming

Mark Bini & Daniel Ahn

Companies should mark their calendars now — expect criminal tariff evasion cases in 2026.

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The FCA As a Policy Instrument Image

The FCA As a Policy Instrument

Ellen M. Murphy & Edward V. Arnold & E. Scott Morvillo

Over the past year, the current administration has redefined the False Claims Act from a traditional anti-fraud statute into a highly flexible policy instrument to enforce its core agenda priorities.

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Expansion of French Parliamentary Inquiries Increases Likelihood that U.S Companies Will Face Investigations Image

Expansion of French Parliamentary Inquiries Increases Likelihood that U.S Companies Will Face Investigations

Raphael Gauvain

The expansion of French parliamentary inquiries, coupled with a persistent climate of suspicion toward U.S. corporate influence, significantly increases the likelihood that international — especially American — companies will face targeted investigations.

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Legal Experts Say Federal Enforcement of White-Collar Crime Laws Has Significantly Receded Under the Trump Administration Image

Legal Experts Say Federal Enforcement of White-Collar Crime Laws Has Significantly Receded Under the Trump Administration

Dan Novak

Federal enforcement of laws against white-collar crime has significantly receded under the Trump administration, with regulators and prosecutors pulling back from the front-end rules meant to stop money laundering and foreign bribery before it occurs, according to legal experts.

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Recent Supreme Court and Second Circuit Decisions Have Reshaped Wire Fraud and Honest-Services Fraud Law Image

Recent Supreme Court and Second Circuit Decisions Have Reshaped Wire Fraud and Honest-Services Fraud Law

Sidhardha Kamaraju & Katherine Reilly & Aaron Wiltse

The limits on wire fraud prosecutions are continuing to evolve, with courts pushing back on further narrowing the scope of the wire fraud statute post-Ciminelli and Percoco.

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There Are Limits to Congress’s Investigatory Powers Image

There Are Limits to Congress’s Investigatory Powers

Harry Sandick & Eric Beinhorn & Kate Ross

Businesses across all sectors of the economy should be knowledgeable about how best to respond to a Congressional investigation, and ultimately, if the investigatory Committee is not satisfied with voluntary compliance efforts, the options available to them for objecting to a Congressional subpoena.

Features

Use a WISP to Detail Data Security Processes and Controls Image

Use a WISP to Detail Data Security Processes and Controls

Alfred R. Brunetti

The written information security plan (WISP) is not just another compliance document, it's a practical roadmap that turns abstract data protection duties into concrete business practices.

Features

SEC Halts Substantive Review of Public Company Requests to Exclude Certain Shareholder Proposals Image

SEC Halts Substantive Review of Public Company Requests to Exclude Certain Shareholder Proposals

Chris O'Malley

A U.S. Securities and Exchange Commission decision to halt substantive review of public company requests to exclude certain shareholder proposals has investor groups concerned their voices will be diminished in U.S. corporate governance.

Features

Proposed Regulation Would Ban Money Laundering As Pretext for Policing Banks’ Reputational Risk Image

Proposed Regulation Would Ban Money Laundering As Pretext for Policing Banks’ Reputational Risk

Dan Novak

The Federal Deposit Insurance Corp. and the Office of the Comptroller of the Currency, in its proposed rule, said that the “broad nature” of BSA and anti-money laundering supervision creates “a risk that BS/AML focused supervisory actions could indirectly address reputation risk.”

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