• 10.01.15

    Add-On Products Add up to $63M Settlement With FDIC

    Credit card add-on products were the subject of a recent enforcement action brought by the Federal Deposit Insurance Corporation (FDIC) against Comenity Bank of Delaware and Comenity Capital Bank in Utah.

  • 09.21.15

    New DOJ Policy Alert: Here's Looking at You, Kid

    On September 9, 2015, Deputy Attorney General Sally Quillian Yates issued a memo to all DOJ department heads and U.S. Attorneys which detailed the Government's new policy centered on accountability for the individuals who are alleged to have perpetrated corporate misconduct.

  • 09.08.15

    No Dog Days of August for the SEC—a Recap of A Busy Month

    Who says there is a government slowdown in August?

  • 08.05.15

    Are the Circuits A-Splitting?

    On July 6, 2015, the Ninth Circuit in U.S. v. Salman declined to adopt a narrow interpretation, arguably set by the Second Circuit in U.S. v. Newman in 2014, of the "personal benefit" element of insider trading cases.

  • 06.30.15

    The Unfolding FIFA Scandal: Will the DOJ Show the Banks a Red Card?

    The worldwide soccer community has for years decried the brazen corruption that permeated FIFA, international soccer’s governing organization, but FIFA remained seemingly impervious . . . until now.

  • 05.29.15

    It’s an Absolute Privilege to Meet You!

    On May 15, 2015, the Texas Supreme Court ruled that an internal investigation report provided by Shell Oil Company to the DOJ in 2009 in connection with an FCPA investigation enjoys “absolute privilege” and therefore cannot be the basis for a defamation case against the company.

  • 04.21.15

    It’s Stifling in Here!

    On April 1, 2015, the SEC announced its first-ever enforcement action against a company for using restrictive language in confidentiality agreements with witnesses interviewed during internal investigations that has the potential to improperly stifle whistleblowers and impede the whistleblowing ...

  • 03.26.15

    Operation Chokepoint Yields Deals With Two California Banks

    A pair of settlements between the Department of Justice (DOJ) and two California banks recently demonstrated that Operation Chokepoint is alive and well.

  • 03.19.15

    The SEC’s Settlement with Goodyear: A Cautionary Tale

    In a settlement announced on February 24, 2015, the SEC found Goodyear to be in violation of the FCPA in connection with bribes paid by two foreign subsidiaries, one of which came into Goodyear’s ownership through acquisition.

  • 03.28.13

    BSA Compliance Fails, Go to Jail

    For many years the government has encouraged directors and officers of corporations to ensure that they have robust compliance programs to detect and prevent violations of law.

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