SEC FCPA Enforcement Action against Goodyear and Investigation of Mondelez...
Action Item: The Securities and Exchange Commission’s enforcement action against Goodyear Tire & Rubber Company and its investigation of Mondelēz International provide key...
View ArticleSEC FCPA Enforcement Action against Goodyear and Investigation of Mondelez...
The Securities and Exchange Commission’s enforcement action against Goodyear Tire & Rubber Company and its investigation of Mondelēz International provide key lessons to U.S....
View ArticleBE-10 Report: The Overlooked International Reporting Form-The June 30...
Action Item: U.S. persons owning an interest in a foreign affiliate may have an obligation to file a BE-10 report by June 30, 2015. Such U.S. persons must act quickly to determine whether they...
View Article'Required Records' Decision Erodes Taxpayers' Fifth Amendment Rights
Few rights are more sacrosanct than the constitutional privilege against self-incrimination. This right extends beyond making statements to police or testifying in court, but also to the act of...
View ArticleThe Use of 'John Doe' Summons to Enforce US Tax Laws
Individuals who have been hiding funds in accounts at Belize Bank International Ltd., also known as Belize Bank Ltd., will soon be known to the Internal Revenue Service by...
View ArticleJudicial Aids to Navigation: Charting the Boundaries of Environmental...
Recent decisions in several federal district and appellate courts have addressed and resolved a number of key issues regarding the procedural and substantive scope of the government’s...
View ArticleMainbrace: January 2016 (No. 1)
To read the full text of the articles in the January 2016 edition of Mainbrace, please download the PDF. A Note from the Vice-Chair, and Co-Chair of the Maritime Industry...
View ArticleFATCA Update: Treasury Issues Long-Awaited Rules For Foreign Asset Reporting...
Action Item: Nearly six years after Congress passed the Foreign Account Tax Compliance Act (FATCA), the Treasury Department has finally issued Final Regulations mandating the reporting of foreign...
View ArticleWith Conclusion of Swiss Bank Program, U.S. Department of Justice Sends...
As 2016 unfolds, the U.S. Justice Department and the Internal Revenue Service continue their unrelenting crackdown on offshore tax evasion, with particular focus on foreign banks and their officers,...
View ArticleDOJ Announces FCPA Pilot Program in an Effort to Incentivize Companies to...
Action Item: On April 5, 2016, the U.S. Department of Justice (“DOJ”) issued a memorandum laying out a one-year pilot program designed to offer mitigation credit to companies that...
View ArticleWith Comprehensive Panama Papers Database to Be Released Today, and White...
Action Item: Today at 2:00 p.m. (EDT), a massive database of information from the leaked “Panama Papers” files will be made public for the first time, identifying the real owners...
View ArticleMAINBRACE: JUNE 2016 (No. 3)
To read the full text of the articles in the June 2016 edition of Mainbrace, please download the PDF. ARTICLES A Note from the Editor by Thomas H. Belknap, Jr. Thank you. Everyone...
View ArticleUnanimous Supreme Court Decision Will Significantly Increase the Ability of...
Action Item: Last week, in a unanimous decision in Salman v. U.S., the U.S. Supreme Court affirmed the Ninth Circuit’s interpretation of insider trading rules, permitting prosecutions even when the...
View ArticleFinancial Services Firms Must Evolve Anti-Corruption Programs in Light of...
Action Item: Global financial services firms should be aware that the DOJ and SEC are committed to identifying and investigating bribery and corruption regardless of the form it takes. With increased...
View ArticleIRS Announces Plans to Move Forward with Passport Revocation Program
Action Item: U.S. citizens who owe more than $50,000 in unpaid federal taxes are at substantial risk of having their U.S. passports revoked within the next few months and should contact counsel for...
View ArticleBridging the Gap: AMLC Launches Government Relations Initiative to Further...
The scenario is a familiar one to lawyers practicing in maritime and admiralty law – a frantic middle-of-the-night call, a shipboard emergency, and your client looking to you for answers in a...
View ArticleWhite Collar Watch: March 2017 (Vol. I, Issue 1)
Welcome to the inaugural edition of White Collar Watch, a relaunch of Blank Rome’s White Collar Defense and Investigations group quarterly newsletter. NOTE FROM THE EDITORS Blank...
View ArticleThe Global Corruption Corner: A Primer to the Foreign Corrupt Practices Act
Any company doing business abroad is subject to the long reach of the Foreign Corrupt Practices Act (“FCPA”). Small or privately-held companies, just like large or public companies,...
View ArticleThe FinTech Revolution: An Introduction to Financial Technology
This article is the first in a series of articles on this topic by the authors. “FinTech” has become a buzzword of the decade. The term, which is a moniker for “financial...
View ArticleNew York Department of Financial Services Implements New...
As of March 1, 2017, New York financial institutions subject to the oversight of the New York Department of Financial Services (“DFS”) are required to comply with a new...
View ArticleIRS Announces Plans to Move Forward with Passport Revocation Program
United States citizens who owe more than $50,000 in unpaid federal taxes are at substantial risk of having their U.S. passports revoked within the next few months and should contact counsel for help...
View ArticleU.S. Department of Justice Issues New Guidance on Corporate Compliance Programs
The U.S. Department of Justice Criminal Division, Fraud Section (“DOJ”), recently published new guidance on corporate compliance programs. All corporate counsel, officers, and...
View ArticleMainbrace: March 2017 (No. 2)
To read the full text of the articles in the March 2017 edition of Mainbrace, please download the PDF. A Note from the Chair by John D. Kimball What’s different about...
View ArticleNew Jersey Attorney General Announces Two New Incentives Programs to Generate...
Action Item: The New Jersey Attorney General’s Office has announced two programs to combat public corruption. Corporations self-reporting corruption may seek a waiver of prosecution, while individuals...
View ArticleIRS Criminal Investigation Division Announces New Priorities
At the ABA Section of Taxation’s 2017 May Meeting, Erick Martinez, the IRS Criminal Investigation Division’s Director of Field Operations – Northern Area, provided insight...
View ArticleIn Rare Victory for Corporations, Supreme Court Limits SEC Power with...
Action Item: Last week’s Supreme Court of the United States decision in Kokesh v. SEC will significantly limit the Securities and Exchange Commission’s (“SEC”)...
View ArticleHigh Court Eliminates Joint and Several Liability among Co-Conspirators
On June 5, the U.S. Supreme Court handed down a decision that will impact sentencing in virtually every criminal case that involves multiple defendants (or multiple conspirators) and the imposition of...
View ArticleWhite Collar Watch (July 2017 • Vol 1, Issue 2)
To view the July 2017 edition of Blank Rome's White Collar Watch, please click here. Welcome to the July 2017 edition of White Collar Watch, Blank Rome’s White...
View ArticleBlowing the Whistle: Employers Must Properly Respond to Employee Allegations...
The Occupational Safety and Health Administration’s ("OSHA") Whistleblower Protection Program enforces the whistleblower provisions of 22 statutes protecting employees who...
View ArticleOverview of IRS Penalties for Individuals with Foreign Bank Accounts and...
Earlier this spring, the Internal Revenue Service ("IRS") Large Business and International Division identified several "campaigns" or areas where it plans to focus...
View ArticleRecord-Setting Prosecutions in the Money Transmitting Business: Ways to Avoid...
In the first several months of 2017, we have seen significant anti-money laundering settlements and penalties in the money transmitting business arising from lax compliance programs, including the...
View ArticleThe Sessions Memo: A Significant Reversal of Policy?
In May 2017, Attorney General Jeff Sessions issued a memorandum to U.S. attorneys, ordering all federal prosecutors to "charge and pursue the most serious, readily provable offense"...
View ArticleFCPA under the New Administration
The single most frequently asked question by our international clients over the past several months is whether there will be changes in white collar prosecution priorities under the new administration,...
View ArticleAt the Intersection of Cybersecurity and White Collar
The global "ransomware" cyberattack in early May 2017 resulted in tens of thousands of computer systems being taken hostage by hackers and, in the instances involving hospitals, put...
View ArticleThe FinTech Revolution: Enforcement Actions Brought against FinTech Companies...
This is the second installment in a series of articles. For an understanding of FinTech products and services and how they are disrupting the financial services industry, please read our first article...
View ArticleFCPA Under the New Administration
The single most frequently asked question by our international clients over the past several months is whether there will be changes in white collar prosecution priorities under the new...
View ArticleThe Sessions Memo: A Significant Reversal of Policy?
In May 2017, Attorney General Jeff Sessions issued a memorandum to U.S. attorneys, ordering all federal prosecutors to “charge and pursue the most serious, readily...
View ArticleFintech Alert: SEC Advises That an Unincorporated Virtual Organization That...
Action Item: The Securities and Exchange Commission (“SEC”) has provided guidance for digital currency offerings that may run afoul of the U.S. securities laws. Investors, token...
View ArticleWhistle While You Work: Recent OSHA Actions Reinforce the Importance of...
The Occupational Safety and Health Administration’s (“OSHA”) Whistleblower Protection Program enforces the whistleblower provisions of 22 statutes protecting employees who...
View ArticleWhere Pseudonymous Cryptocurrency Transactions Meet AML Reporting Requirements
Two months ago, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), working with the U.S. Attorney’s Office for the Northern District of...
View ArticleMainbrace: October 2017 (No. 4)
To read the full text of the articles in the October 2017 edition of Mainbrace, please download the PDF. Note from the Maritime Industry Team by Richard V. Singleton II Large sectors of the maritime...
View ArticleMajor Changes to Justice Department Policies May Be Coming
Action Item: Recent remarks by Deputy Attorney General Rod Rosenstein suggest that the U.S. Department of Justice may be consolidating its policies—which are normally articulated through...
View ArticleFinTech Alert: SEC’s New Cyber Unit Brings First Enforcement Action in...
Action Item: The U.S. Securities and Exchange Commission (“SEC”) announced that its newly formed cyber unit has filed its first charges in connection with an Initial Coin Offering...
View ArticleDOJ Incorporates FCPA Pilot Program into U.S. Attorneys' Manual Providing...
Action Item: The U.S. Department of Justice (“DOJ”) recently included the principles of its Foreign Corrupt Practices Act (“FCPA”) Pilot Program into the U.S....
View ArticleThe FinTech Revolution: The Impact of Blockchain Technology on Regulatory...
This is the third installment in a series of articles. For more background on this topic, please read our first article in the series, An Introduction to Financial Technology, and our second article,...
View ArticleThe Criminal Finances Act of 2017: New Compliance Requirements for UK Businesses
On April 27, 2017, the United Kingdom enacted the Criminal Finances Act 2017 (the "Act"), which provides that companies and partnerships ("relevant bodies") are...
View ArticleThe Benefits of Corporate Anti-Corruption Programs: No Charges
The U.S. Department of Justice ("DOJ") and the Securities and Exchange Commission ("SEC") issued 15 declination letters in 2017 notifying companies of their decision...
View ArticleWhite Collar Watch (December 2017 • Vol. 1, Issue 3)
To view the December 2017 edition of Blank Rome's White Collar Watch, please click here. Welcome to the December 2017 edition of White Collar Watch, Blank Rome’s White Collar...
View ArticleIRS Focuses Its Audit Priorities on Captive Insurance
The terms "captive insurance" and "federal income tax code" are anything but captivating. Yet, captive insurance has captivated the attention of the Internal Revenue...
View ArticleAppreciating Bitcoin: A Holiday Guide to Legal Hot Topics in Virtual Currency
Five years ago, one bitcoin sold for less than $15. Two years ago, the unit price was about $500. Now, the price of a bitcoin has topped $15,000, and it’s climbing fast enough to...
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