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SEC Takes Aim at Political Contributions by Investment Advisers
April 01, 2017
While it remains unclear both when the regulators will invoke their authority to enforce the nearly limitless strict liability provision of the rules and how they will determine the appropriate remedy, the recent settlements and the SEC's handling of exemptive relief petitions may provide some clues.
The Clock Is Ticking
In the aftermath of the financial crisis, government regulatory agencies, such as the SEC, have aggressively pursued civil enforcement actions to combat financial fraud. However, their efforts to extend their ability to seek monetary penalties and fines outside of relevant limitations periods have been recently rebuffed by the courts.
The Battle over the Scope of Rule 17(c) Subpoenas
Before considering the competing, less restrictive, interpretation of Rule 17(c), we briefly pause to explain how we got here. The restrictive interpretation of Rule 17(c) has its genesis in two Supreme Court decisions.
Third-Party Money Launderers<br><i><font size="-1">The FBI Takes a Second Look</i></font>
Each year, the U.S. government secures more than 1,200 money-laundering convictions. Now, the Federal Bureau of Investigation (FBI), at least, is setting its sights with renewed vigor on those who help criminal organizations and terrorists conceal billions in illicit funds.
In the Courts
The Fifth Circuit recently clarified the Anti-Kickback Act. Here's an analysis of the ruling.
Business Crimes Hotline
Update on the DOJ's collection of billions in enforcement actions from Volkswagen and Rolls Royce.
Third-Party Money Launderers
March 01, 2017
Each year, the U.S. government secures more than 1,200 money-laundering convictions. Now, the Federal Bureau of Investigation (FBI), at least, is setting its sights with renewed vigor on those who help criminal organizations and terrorists conceal billions in illicit funds.
Criminal Immigration Enforcement vs. Employers: Will It Be the New Normal?
February 01, 2017
Increased enforcement of the immigration laws that impact on the hiring of employees is on the horizon.
The 'Panama Papers' and You<br><font size="-1"><b><i>Part Two of a Two-Part Article</b></i></font>
February 01, 2017
Last month, the authors began a discussion of the legal consequences of the release of the so-called "Panama Papers," a trove of more than 11.5 million documents a whistleblower gave to a reporter at the German newspaper Süddeutsche Zeitung (SZ) in Spring 2016. The authors conclude their analysis herein.
The Battle over the Scope of Rule 17(c) Subpoenas<br><font size="-1"><b><i>Part One of a Two-Part Article</b></i></font>
February 01, 2017
White-collar prosecutions often turn on the paper trail. But the playing field is not level — not even close.

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