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White Collar Briefly

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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. 

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March 23, 2020

The Hidden Magic of Mandatory Crime Reporting Laws

Attorneys counseling companies on white collar matters are likely to have discovered crimes such as theft, bribery, and embezzlement committed by current and former employees, as well as by competitors. 

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January 27, 2020

DSIO and NFA Share Views on Evolving Swap Dealer Oversight

The U.S. Commodity Futures Trading Commission's (CFTC) Director of the Division of Swap Dealer & Intermediary Oversight (DSIO), alongside fellow panelist and National Futures Association's (NFA) General Counsel, fielded wide-ranging questions from co-panelists and audience members alike in a discussion focused on Intermediaries & Advisors at the ABA's Derivatives & Futures Law Committee Winter Meeting in Naples, Florida (January 23-25, 2020). View blog post
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October 31, 2019

Crime Doesn’t Pay, But Defendants Still Left with the Bill

The U.S. Court of the Appeals for the Ninth Circuit recently held that criminal defendants who gain unlawful proceeds from certain offenses must pay back those proceeds—even when they no longer possess them.

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International
October 24, 2019

Germany Proposes New Corporate Sanctions Act with Global Reach

The German Federal Ministry of Justice and Consumer Protection recently presented draft legislation to Parliament that could pose a marked shift in how corporate crimes are sanctioned in Germany.

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Financial Services & Investments
October 4, 2019

DOJ Brings Novel RICO Charges Against Alleged Spoofers

The DOJ has raised the stakes in criminal spoofing enforcement, unveiling sweeping charges against three traders who allegedly conspired to manipulate the precious metals market.

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September 24, 2019

DOJ Leveraging Data Analytics To Detect Fraud

The DOJ is increasingly using a "data focused approach" to identify economic crime and corporate misconduct, according to a DOJ official.  

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Gavel and Scales
September 12, 2019

Second Circuit Affirms Broad Reading of Sec. 666 Bribery

The Supreme Court's 2016 decision in United States v. McDonnell raised questions about the constitutionality of expansive interpretations of federal bribery statutes.  

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Buildings London
September 10, 2019

UK Regulator Sets High Bar for Corporate Cooperators

Last month, the UK Serious Fraud Office ("SFO") published non-binding, internal guidance expanding on its view of corporate cooperation in prosecutions. 

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Government
August 12, 2019

American Indian Tribes and “Foreign Officials” Under the FCPA

One of the many challenges companies face when assessing their Foreign Corrupt Practices Act ("FCPA") liability is determining whether a potential business partner constitutes a "foreign government official" under the FCPA.

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Supreme Court Outside
May 10, 2019

Supreme Court Declines to Resolve Circuit Split Over Liability in Tender Offer Suits

Section 14(e) of the Securities Exchange Act prohibits deceptive conduct when making a tender offer to shareholders. 

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Buildings London
April 4, 2019

UK’s Impending “Name and Shame” for Supply Chain Forced Labor

The U.K. Modern Slavery Act of 2015 requires companies falling under its jurisdictional hook to honestly and completely disclose their efforts to eradicate trafficked, slave, indentured, coerced and child (collectively "forced") labor from their supply chains. 

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Education
March 25, 2019

Higher Ed: Admissions Scandal Wake Up Call

The arrests in the college admissions bribery scandal may have ushered in a new era of scrutiny by federal law enforcement.

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March 11, 2019

CFTC Dips Its Toe into Anti-Corruption Space

On March 6, 2019, the Division of Enforcement of the U.S. Commodity Futures Trading Commission ("CFTC") issued a new Enforcement Advisory on self-reporting violations of the Commodity Exchange Act ("CEA") involving foreign corrupt practices. View blog post
Gavel with scale
February 12, 2019

Revisiting Agency Liability Under the FCPA Post-Hoskins

In United States v. Hoskins, 902 F.3d 69 (2d Cir. 2018) the Second Circuit held that a non-resident foreign national cannot be criminally liable for aiding and abetting or conspiring to violate the FCPA unless the government can establish that such an individual acted as an agent of one of the categories of persons subject to liability as a principal. Background The DOJ charged Lawrence Hoskins, a British national and former Alstom UK executive based in Paris, with FCPA and money-laundering violations. View blog post
Government
January 22, 2019

SEC’s Polycom FCPA Settlement Leaves Unanswered Questions

On December 26, 2018, the Securities and Exchange Commission ("SEC") announced a settlement with communications technology firm Polycom, Inc.

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