Sky Blog
On June 5, 2025, the Head of the Criminal Division of the Department of Justice (“DOJ”), Matthew R. Galeotti, issued a memorandum providing guidance to Criminal Division prosecutors on corporate resolutions involving parallel criminal, civil, regulatory, and administrative proceedings by …
In a recent article, we explore the curious case of how regulators in the EU, UK, and United States treat two forms of insider trading — what we call “traditional insider trading” and “shadow trading.” The former, familiar to …
Earlier this year, Judge Reed O’Connor made headlines when he rejected a plea agreement between the Department of Justice (“DOJ”) and Boeing. O’Connor rejected the agreement because it required the DOJ to consider its DEI policies in selecting a corporate …
On May 19, 2025, the U.S. Deputy Attorney General issued a memorandum (the “Memo”) announcing a Civil Rights Fraud Initiative (the “Initiative”) and instructing the U.S. Department of Justice (“DOJ”) to pursue False Claims Act (“FCA”) enforcement against “any recipient …
In a notable decision issued on May 22, 2025, Kousisis v. United States, the U.S. Supreme Court held that a defendant may be convicted of wire fraud under 18 U.S.C. § 1343 even when the scheme does not result in …
On May 12, 2025, the Head of the Department of Justice’s (“DOJ”) Criminal Division, Matthew R. Galeotti, announced significant changes to the Criminal Division’s corporate and white-collar enforcement policies and priorities.[1] Speaking at the Securities Industry and Financial Markets …
Key Points
On May 9, 2025, President Trump issued an Executive Order that purports to reduce regulatory burdens and ensure that “no American is transformed into a criminal for violating a regulation they have no reason to know exists.” The Executive Order …
On April 30, 2025, the Department of Justice’s (“DOJ”) National Security Division (“NSD”), alongside the U.S. Attorney’s Office for the Northern District of California, announced a declination to prosecute Universities Space Research Association (“USRA”) for criminal export control violations committed …
On April 25, 2025, Attorney General Pam Bondi announced a new policy, rescinding the prior administration’s policies that restricted prosecutors from seeking records or compelling testimony from news organizations in leak probes.[1] This policy substantially lowers internal hurdles for …
I argue in a forthcoming article[1] that when corporate misconduct results in someone’s death, resolving the ensuing criminal charges with a “C” plea bargain can be antithetical to the pursuit of justice. To support my argument, I examine one …
The U.S. Department of Justice (DOJ or Department) has announced a significant shift in enforcement priorities concerning digitalassets. On April 7, 2025, Deputy Attorney General Todd Blanche issued a memorandum (Memorandum) announcing that the Department is not a “digital assets …
On April 11, 2025, the National Security Division (NSD) of the Department of Justice (DOJ) issued a press release and multiple guidance documents on its final rule on “Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries …
On April 7, 2025, Deputy Attorney General Todd Blanche issued a memo (the “Blanche Memo”) announcing the Trump administration’s Department of Justice (“DOJ”) refocus of enforcement policies related to investigations and prosecutions of individuals and entities involved with digital assets. …
Shifting U.S. enforcement priorities may soon create a crisis in international anti-corruption efforts. For decades, the United States spearheaded those efforts through prosecutions under the Foreign Corrupt Practices Act (FCPA). On February 10, however, President Donald Trump issued an Executive …
On April 7, 2025, Deputy Attorney General Todd Blanche issued a memorandum to all Department of Justice employees (the “Memorandum”) announcing an overhaul of previous enforcement directives relating to digital assets. The Deputy Attorney General issued the Memorandum consistent with …
Policymakers around the world have typically outsourced the detection of financial crime to the private sector. This approach is often referred to as the “gatekeeper” model, with the basic idea being that private firms, like bodyguards at a nightclub, are …
On February 12, President Trump issued an Executive Order and Fact Sheet ordering, among other things, that the U.S. Attorney General cease initiation of any new FCPA investigations or enforcement actions for 180 days. As CEOs and boards of …
On March 11, 2008, Congress held its first ever hearing on corporate monitors. The hearing began with questions to John Ashcroft, the former U.S. Attorney General who then headed a law and consulting firm, about why he had been given …
FinCEN announced that it will not impose fines or penalties on companies that do not submit their beneficial ownership information reports by the upcoming deadline of March 21, 2025. The agency will issue an interim final rule to establish new …