White Collar Briefly
White Collar Briefly
Drawing from breaking news, ever changing government priorities, and significant judicial decisions, this blog from Perkins Coie’s White Collar and Investigations group highlights key considerations and offers practical insights aimed to guide corporate stakeholders and counselors through an evolving regulatory environment. Subscribe 🡢
FinCEN Issues Highly Anticipated Final Rule on Beneficial Ownership Reporting under the Corporate Transparency Act
On September 29, 2022, the Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") issued its highly anticipated Final Rule implementing the beneficial ownership information ("BOI") reporting requirements of the Corporate Transparency Act ("C
DOJ Announces Sweeping Policy Updates Targeting Corporate Criminal Enforcement and Individual Accountability
DOJ Secures Spoofing Conviction, but Loses on Novel RICO Charges
Court Holds Oral Downloads of Witness Interviews Waive Corporate Privilege
In a criminal case against two former officers of Cognizant Technology Solutions Corp.
SCOTUS Rejects Negligence Standard in ‘Pill Mill’ Cases
The US Supreme Court in Ruan sided with doctors seeking a burden of proof higher than mere negligence in prosecutions for unlawful distribution of controlled substances.
Talking Jury Selection With JurorSearch CEO Dan Johnson
JurorSearch CEO and Co-Founder Dan Johnson sits down with Perkins Coie White Collar & Investigations Partner Markus Funk to discuss some of the latest developments in jury selection.
U.S. Treasury Renews Focus on AML Risks for Investment Advisors
Glencore Resolves Charges of Global Corruption and Market Manipulation
On May 24, 2022, Glencore International A.G. ("Glencore"), a multi-national resource extraction and commodities trading company, pleaded guilty in the Southern District of New York to one count of conspiracy to violate the anti-bribery provision of the Foreign Corrupt Pract
Could It Be Easier to Convict a Doctor Than a Cartel Member? Why the Impending SCOTUS “Pill Mill” Ruling Makes Some Observers Nervous
The U.S. Supreme Court is poised to issue what could be a monumental decision in the Court's Controlled Substances Act ("CSA") jurisprudence as applied to the nation's opioid epidemic.
Shadow Trading: Examining the SEC’s Insider Trading Theory in SEC v. Panuwat
On January 14, 2022, a federal district court in the Northern District of California declined to dismiss the first-ever enforcement action by the U.S.
As Russia Sanctions Mount, FinCEN Issues Advisory on Kleptocracy and Foreign Public Corruption
On April 14, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an advisory focusing on detecting kleptocrats (i.e., government officials who appropriate national resources for personal gain) and the proceeds of foreign public corruption and preventing t
Internal Investigations: Law on Work Product & Attorney-Client Privilege
Following up on a recent Public Chatter blog in a series about internal investigations, note that Federal Rule of Evidence 502(g) states:
New DOJ Guidelines Regarding FOIA Create Presumption of Openness
Background on the Guidelines and FOIA On March 15, 2022, the United States Department of Justice ("DOJ") released new guidelines favoring the disclosure of federal agency 
DOJ Foreshadows Increased Prosecutions of Corporate Crime
In remarks to the ABA Institute on White Collar Crime, U.S. Attorney General Merrick Garland and U.S.
SEC v. Team Resources, Inc.: Exploring SEC Disgorgement Post-Liu
Recent briefing in SEC v. Team Resources, Inc., a long-running case challenging a U.S. Securities and Exchange Commission ("SEC") disgorgement award, is a reminder of both the significance of the Supreme Court's 2020 decision in Liu v. SEC and the open questions that remain regarding the SEC's disgorgement remedy.