On November 4, 2021, the Department of Defense (DoD) announced significant changes to the strategic direction of the Cybersecurity Maturity Model Certification (CMMC) program. Specifically, DoD stated that the goal of these changes is to simplify the CMMC standard and prioritize the protection of certain types of controlled defense information. After a nine-month internal review
Subject to Inquiry
SEC Advisory Fees Focus Continues as Reflected in Division of Examinations Risk Alert and Chair Gensler Comments
Recent comments from U.S. Securities and Exchange Commission (SEC) Chair Gensler at the Institutional Limited Partners Association Summit and an SEC Division of Examinations (EXAMS) Risk Alert published on the same day highlight the ongoing focus of the SEC on advisory fees, both in the institutional and retail spaces.
In Chair Gensler’s remarks, he…
Webinar: OSHA ETS Employee COVID-19 Vaccination and Testing Mandates
New Requirements, Tips and Traps for Large Employers
November 10, 2021
Complimentary Webinar
1-2 p.m. (ET) | 12-1 p.m. (CT) | 10-11 a.m. (PT)
On Nov. 4, 2021, the Occupational Safety and Health Administration (OSHA) issued an Emergency Temporary Standard (ETS) requiring employees of large employers either to get vaccinated or to test negative…
Return to the Yates Memo: Deputy Attorney General Announces Tougher Approach to White Collar Enforcement
On October 28th, Deputy Attorney General Lisa Monaco announced that the U.S. Department of Justice (DOJ or Department) is renewing its focus on white collar crime and enforcement, in remarks delivered during the American Bar Association’s 36th National Institute on White Collar Crime. Monaco made clear that the Department is significantly enhancing its efforts to…
The Perils of Global Expansion: World’s Largest Ad Agency Sanctioned $19 Million for FCPA Violations, Insufficient Controls
Global expansion without adequate controls is asking for trouble. That’s the lesson of a $19 million settlement between WPP, the world’s largest advertising agency, and the U.S. Securities and Exchange Commission (SEC) to resolve alleged violations of the Foreign Corrupt Practices Act (FCPA).
According to an SEC order memorializing the settlement, WPP’s trouble began when…
Department of Justice Announces National Cryptocurrency Enforcement Team
On October 6, 2021, the U.S. Department of Justice (DOJ) announced its plans for increased scrutiny of the cryptocurrency market with the creation of a National Cryptocurrency Enforcement Team (NCET) to pursue criminal investigations and actions against cryptocurrency misuse. The NCET will focus on “crimes committed by virtual currency exchanges, mixing and tumbling services, and…
Department of Justice Announces Increased FCA Enforcement Through New Civil Cyber-Fraud Initiative
On October 6, 2021, the Department of Justice (DOJ) announced a new Civil Fraud Cyber Initiative to “combine the department’s expertise in civil fraud enforcement, government procurement and cybersecurity to combat new and emerging cyber threats to the security of sensitive information and critical systems.”…
Gleanings From DOJ’s 2021 Healthcare Takedown Announcement
On Sept. 17, the U.S. Department of Justice released the results of its 2021 Healthcare Takedown — an annual announcement aggregating months of investigations and indictments across the country involving fraud in the healthcare and life sciences industries.
Read on for details and analysis of criminal charges against 138 defendants, including 42 medical professionals, related…
DOJ Title IX Investigation Leads to $1.6M Agreement with San Jose State University
The Department of Justice’s Civil Rights Division, the U.S. Attorney’s Office for the Northern District of California, and San Jose State University (SJSU) settled the government’s Title IX investigation into a decade’s worth of sexual harassment allegations. The June 2020 allegations of “employee-on-student sexual harassment” and retaliation within the University’s athletics department prompted the government’s…
Corporate Campaign Contributions Are a Crime, Independent Expenditures Legitimate: Sixth Circuit Explains the Difference
The Sixth Circuit has upheld the felony conviction of a former state party chair for illegal campaign contributions by a corporation he owned, in a case that both serves as an important reminder of the prohibition on corporate contributions to federal campaigns and shows that the Justice Department may be stepping up criminal election law…