Features

Shifting Crypto and Cyber Priorities In SEC Enforcement
When the SEC issues the next annual enforcement report for fiscal year 2025, we expect securities offering actions and investment adviser actions will almost certainly be up, and the “crypto” and “cyber” cases will almost certainly be down. Public statements by the new SEC administration have said as much, but even more telling than public statements are the allocation of limited enforcement resources.
Features

How Prepared Are You for Trump 2.0’s Worksite Enforcement Regime?
As the first months of the new administration have demonstrated, President Trump fully intends to deliver on the campaign promise to “restart workplace enforcement.” Employers should prepare now to confirm their employees are authorized to work and have robust compliance policies and procedures in place should ICE come knocking.
Features

First Circuit Adds to Split On Whether Use of the Internet Is ‘Interstate Commerce’
The internet is generally viewed as inherently interstate in nature, but courts have reached different conclusions as to whether use of the internet by itself satisfies the “interstate commerce” requirement in criminal statutes, or something more is needed.
Features

AI-Related Securities Class Actions On the Rise
Understanding the types of challenges shareholders are bringing against AI-affiliated companies is critical to effectively evaluating proposed disclosures and addressing potential areas of exposure.
Features

Shift In Foreign Corruption Policy Could Amplify Risk of Extortion for Global Businesses
The Trump administration’s shift in enforcement policy away from foreign corruption and towards the fight against Transnational Criminal Organizations (TCOs) such as drug cartels, may reduce the immediate risk to global businesses of an FCPA prosecution based on alleged extortion payments. However, the same shift raises new threats to those businesses under statutes that prohibit engagement of any kind with terrorist organizations, do not recognize an extortion defense, and may give rise to civil as well as criminal liability.
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