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Despite the active hostility of the Chinese, Indian and Russian governments, the spread of bitcoins throughout the world was untrammeled until last month. In a series of dramatic arrests and prosecutions, the U.S. government began an active campaign against the use of bitcoins for questionable purposes.
Yet the bitcoin world seemingly is unaware of the thrust of recent U.S. actions. It was, however, roiled recently by two events. The first was the elimination of Blockchain, a bitcoin wallet app, from the Apple store. The second was the announcement that both Mt. Gox and Bitstamp, prominent bitcoin exchange sites, were halting withdrawals. The latter events were described as the result of technical problems and a denial of service attack, respectively, with no confirmation as to whether Mt. Gox was simply attacked as Bitstamp was. See, “What's Going on with Bitcoin Exchange Mt. Gox,?” TechCrunch.
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.
This article explores legal developments over the past year that may impact compliance officer personal liability.