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Raising the Stakes
The government has become increasingly aggressive in pursuing criminal claims not only against corporations, but also against in-house counsel and compliance personnel, for conduct once treated almost exclusively as civil. This trend creates situations in which a judgment call on the part of an in-house attorney or compliance officer could create real and dire personal consequences. Most recently, the U.S. Treasury Department's Financial Crimes Enforcement Network imposed a $1 million civil penalty against a money services industry compliance officer as a result of a purported failure to ensure his company's compliance with anti-money laundering laws.
The False Claims Act
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New York's Latest Cybersecurity Commitment
On Aug. 9, 2023, Gov. Kathy Hochul introduced New York's inaugural comprehensive cybersecurity strategy. In sum, the plan aims to update government networks, bolster county-level digital defenses, and regulate critical infrastructure.
The DOJ's Corporate Enforcement Policy: One Year Later
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.
How AI Has Affected PR
When we consider how the use of AI affects legal PR and communications, we have to look at it as an industrywide global phenomenon. A recent online conference provided an overview of the latest AI trends in public relations, and specifically, the impact of AI on communications. Here are some of the key points and takeaways from several of the speakers, who provided current best practices, tips, concerns and case studies.
Use of Deferred Prosecution Agreements In White Collar 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.