An Active Year in Enforcement, with Changes to Come
January 16, 2025
The Securities and Exchange Commission (SEC) and Department of Justice (DOJ) both had active enforcement years in 2024.
The SEC’s aggressive focus on crypto enforcement continued, resulting in the filing and continued litigation of several cases in federal courts nationwide. The DOJ announced a number of policy updates in 2024, including guidance related to voluntary disclosures and corporate enforcement, and remained active in the foreign corruption and national security spaces. Finally, both the SEC and DOJ have increased their focus on AI and new technologies, showing increasing concern about the risks associated with AI, with the DOJ issuing guidance on AI in compliance programs and the SEC bringing cases related to misleading marketing about the use of AI in investment strategies. As noted more fully below, with the incoming Trump Administration, enforcement priorities at both SEC and DOJ are expected to shift. The SEC is expected to have a renewed focus on traditional enforcement areas, such as accounting fraud, misrepresentations in securities offerings and insider trading, with significant reductions in enforcement activity related to crypto, cyber incidents and ESG issues. The DOJ is likely to continue its focus on FCPA and national security (including sanctions and export controls), while devoting increasing resources to immigration and violent crime. Additionally, the benefits of cooperation are likely to increase at both the SEC and DOJ, with the potential for reduced penalties for companies able to effectively demonstrate their cooperation and self-remediation.
In anticipation of the incoming Trump Administration, there already have been notable personnel changes at both SEC and DOJ with more to come. Specifically, SEC Chair Gary Gensler and Democratic Commissioner Jaime Lizarraga have announced that they will depart. In addition, Trump has announced the nomination of former Commissioner Paul Atkins as Chair, who will stand to replace the outgoing heads of the Divisions of Enforcement and Corporation Finance, among other positions. On the DOJ side, Attorney General-nominee Pam Bondi and Deputy Attorney General nominee Todd Blanche will work with all-new appointees at the top levels of DOJ. Most of the nominees for those positions have yet to be announced, though the incoming administration has announced the nomination of Gail Slater to head the Antitrust Division and Kash Patel to run the FBI.
Key SEC Developments
The SEC filed 583 total enforcement actions in 2024, a 26% decline from the previous year.[1] Total financial remedies reached $8.2 billion, the highest amount in SEC history and a large increase from the $4.9 billion received in 2023, though more than half that total was attributable to a judgment obtained after the SEC’s jury trial win against blockchain startup Terraform Labs and its founder, Do Kwon.[2] The SEC also continued setting records with its whistleblower program, receiving more than 24,000 whistleblower tips and announcing whistleblower awards of more than $255 million.[3] In announcing their year-end results, the SEC highlighted the importance of self-reporting, noting that “market participants across the spectrum – from public companies to major broker-dealers and advisory firms–stepped up efforts to self-report, remediate, and meaningfully cooperate with our investigations.”[4] The SEC also extolled the virtues of cooperation and remediation by entities facing enforcement investigations, with benefits including reduced or no penalties. The benefits of cooperation are likely to increase under the new administration. Substantively, the SEC maintained its focus on digital assets and traditional areas such as accounting, financial disclosure, and oversight of investment advisers and other regulated entities.
Artificial Intelligence
The SEC’s ramp-up of AI oversight included enforcement actions, new examination priorities, and proposed rulemaking. For example, in March 2024, the SEC announced two enforcement actions against investment advisers for “AI-washing” and violations of the Marketing Rule, alleging that the relevant investment advisers had marketed that they were using AI in certain ways that they allegedly were not. For further discussion, see Effective Board Oversight as AI Evolves.
Digital Assets
Digital assets remained at the forefront of the SEC enforcement agenda, with the agency continuing to bring litigated cases rather than to pursue rulemaking. The SEC continued high-profile litigation cases against three digital asset trading platforms, which are set to extend into 2025.[5] The cases were brought in three different jurisdictions, with the courts so far agreeing only that the digital assets themselves are not securities and that the manner in which the digital asset is sold determines whether there is a securities transaction.[6] After focusing on digital asset issuers and platforms, the SEC for the first time targeted a market maker in connection with its role in facilitating the trading of digital assets. The industry will be paying close attention to these cases that target digital asset infrastructure in the next year. With the nomination of Paul Atkins as Chair, the SEC may take a more restrained approach to digital asset enforcement by turning back to potential rulemaking, if enabled by Congress, instead of litigation, to address this new technology. As such, the SEC is expected to bring fewer cases in this space, likely only where there is potential fraud in the offering of a digital asset. With respect to ongoing litigation, where there is no allegation of fraud or investor harm, the SEC is likely to look for easy settlements or will potentially dismiss cases.
Off-Channel Communications
The SEC continued its sweep of regulated entities’ use of “off-channel communications,” assessing over $600 million in penalties in settled actions against over 70 broker-dealers, investment advisors, municipal advisors and credit-rating agencies that allegedly did not comply with recordkeeping requirements in connection with employees’ use of texting or messaging apps.[7] This initiative has likely run its course, as the two Republican Commissioners who will remain on the SEC have called on the agency to “reconsider [the] current approach to the off-channel communications issue.”[8] More generally, we expect the SEC likely will conduct fewer sweeps designed to condition the behavior of the securities industry and instead focus more of its resources on cases that involve actual investor harm, such as offering frauds, accounting and issuer disclosure fraud and misappropriation of funds by investment advisers.
Cybersecurity
Cybersecurity has risen to the top of the SEC’s list of enforcement priorities. In late 2023, the SEC’s new rules on cyber disclosures took effect, which, among other things, require disclosure on Item 1.05 of Form 8-K within four business days after a registrant determines that it has experienced a material cybersecurity incident.[9]
While the SEC has continued to bring settled cases in this space, it was dealt a significant setback when a court dismissed most SEC fraud claims related to allegedly misleading statements by the software company SolarWinds and its chief information security officer in connection with a massive, state-sponsored cyber intrusion the company suffered.[10] A judge in the Southern District of New York held that most of the company’s statements about its cybersecurity defenses were too generalized to be materially misleading and that the internal controls provisions of the securities laws were meant to apply to accounting controls rather than cybersecurity controls. The court did, however, allow the SEC to proceed on claims that SolarWinds allegedly misled investors by posting a “security statement” on its website that touted its adherence to specific cybersecurity standards that, in the SEC’s view, it was not following. The SolarWinds case, which led to a sweep-style investigation of companies impacted by the breach, symbolized the priority the SEC attached to detailed disclosures of the potential impact of cyber incidents, as demonstrated by multiple enforcement actions in the last several years against companies that were themselves the victims of cyber attacks. In the wake of the court ruling, as well as statements by the Republican commissioners who objected to bringing the SolarWinds case and similar cases targeting victims of cyber-attacks, the SEC is likely to temper its backward-looking scrutiny of companies’ post-incident disclosures and refrain from charging internal controls violations in cybersecurity cases where the company’s accounting and disclosure controls are not specifically implicated.[11]
Key DOJ Developments
In 2024, the DOJ published a number of policy updates and guidance in areas related to corporate enforcement, compliance and the use of AI. This focus was similarly reflected in the hiring of personnel, such as the department’s first Chief Science and Technology Advisor and Chief Artificial Intelligence Officer.[12] Through these policies, the DOJ continued its strategy of incentivizing voluntary self-disclosure by providing specific and quantifiable benefits for self-reporting, including by rolling out a new whistleblower awards pilot program offering bounty payments to individual whistleblowers. The incoming Trump Administration will want to make their imprint through their own DOJ policies, as such we may expect them to withdraw or revise policies that raise the bar on what is required for companies to receive leniency, while keeping in place policies that benefit corporate defendants.[13] In 2024, the DOJ remained focused on corporate enforcement in areas such as FCPA, anti-money laundering, digital assets, and, increasingly, on national security, which is likely to continue with the incoming Trump Administration.
Policy Updates and Guidance
The DOJ issued a number of important policy updates and guidance throughout 2024, with a continued focus on voluntary self-disclosure and ratcheting up pressure on companies to be “first in the door” to self-report misconduct. The DOJ policies seek to achieve this objective by rewarding whistleblowers with monetary awards; offering non-prosecution agreements to culpable individuals who provide actionable information; providing safe harbor for acquiring companies who self-report criminal conduct by an acquired company; and a continued emphasis on maintaining an effective compliance program. These policies are:
- Mergers & Acquisitions Safe Harbor: In another iteration of its emphasis on self-reporting, the DOJ revised the Justice Manual to include a “safe harbor” from prosecution for acquiring companies that self-report criminal conduct by an acquired company identified in due diligence. The Safe Harbor, implemented in March 2024, provides a presumption in favor of DOJ declining to prosecute an acquiring company that voluntarily and promptly self-reports criminal violations by an acquired company, remediates any misconduct and forfeits proceeds of the violation.[14] However, additional requirements apply to potential criminal Sherman Act violations. The Safe Harbor provision does not permit compliant companies that report criminal violations of the Sherman Act by a target to close their acquisition until the DOJ Antitrust Division provides a conditional leniency letter or allows the leniency marker to expire, making it an impractical option for the majority of purchasers.[15]
- The Pilot Program on Voluntary Self-Disclosure for Individuals: In April, the DOJ launched a Pilot Program on Voluntary Self-Disclosure for Individuals to incentivize culpable individuals to self-report their misconduct and cooperate in the DOJ’s investigation and prosecution of other individuals and companies in exchange for non-prosecution agreements (NPAs).[16] Culpable individuals can qualify for an NPA if they are first to report and provide substantial assistance to the prosecution of more culpable individuals or companies in certain core enforcement areas.[17]
The DOJ programs effectively create a race between companies and individuals to report misconduct, as an individual must be “first in the door” in order to receive an NPA or whistleblower award.[18] This likely will leave companies at a disadvantage as it is often easier for individuals to have an understanding of their role in misconduct as compared to companies, especially large, multinational companies. As culpable individuals may be incentivized to report directly to DOJ, companies will need to balance conducting thorough, confidential and complete internal investigations with maintaining confidentiality so as not to “tip off” individuals involved in the misconduct. As the whistleblower and individual self-disclosure programs are pilot programs, it is possible the Trump Administration will not renew them. - Whistleblower Awards Pilot Program: The DOJ’s Whistleblower Awards Pilot Program, launched last August, provides individuals with awards of up to $50 million if they provide original information and cooperate in an investigation leading to more than $1 million in criminal or civil forfeiture in connection with a successful DOJ case related to corporate criminal conduct.[19] Notably, companies that receive internal whistleblower reports are still eligible to obtain credit and the presumption of a declination even if the whistleblower also reported to DOJ, so long as the company (1) self-discloses the allegation to DOJ within 120 days of receiving the whistleblower’s internal report (and before the DOJ contacts the company); and (2) meets the other requirements for voluntary self-disclosure and presumption of a declination under the Corporate Enforcement and Voluntary Self-Disclosure Policy.[20]
- Revisions to the DOJ Criminal Division’s Compliance Guidance (ECCP): In September 2024, DOJ announced revisions to the Criminal Division’s compliance guidance, known as the Evaluation of Corporate Compliance Programs (ECCP).[21] With respect to new AI, the updated guidance reflects efforts to analyze how companies are using new technologies in their businesses, and whether that use is accompanied by an appropriate assessment of the potential risks and vulnerabilities that those technologies may present.[22] The revised ECCP additionally emphasized the importance of companies having processes in place to periodically evaluate their own compliance programs, focusing on continuous improvement through the leveraging of data and analytics tools.[23] Furthermore, DOJ will expect companies to incorporate lessons learned from both their own prior misconduct and from issues at other companies into their compliance programs through trainings that are regularly updated and also to focus on evolving risks for the company and the industry in which it operates. Finally, the ECCP incorporated changes related to whistleblower reporting, emphasizing that prosecutors will assess whether companies are promoting whistleblower reports and are assessing employee willingness to report misconduct, such as testing whether employees are aware of and feel comfortable using reporting hotlines.[24]
FCPA
Enforcement of the Foreign Corrupt Practices Act (FCPA) remained a priority in 2024, with the DOJ entering into eight corporate criminal resolutions and issuing one declination under the Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy, which was revised in 2023.[25] The DOJ’s actions reflect the continued premium placed on voluntary self-disclosure, as well as proactive and full cooperation. To merit a declination, the DOJ has emphasized the timeliness of the disclosure following the discovery of evidence, as well as the full cooperation and remediation by the company, which included termination of responsible personnel and disgorgement of all ill-gotten gains.[26] The DOJ also continued its increasing cooperation with international authorities, including its first coordinated resolution with Ecuador, two additional resolutions coordinated with South Africa, and continued cooperation with authorities from Brazil, Switzerland, Uruguay, Colombia, Singapore, Portugal and elsewhere.[27]
DOJ also continued securing trial convictions and guilty pleas in a number of significant, high-profile foreign bribery matters in multiple jurisdictions. Among others, the DOJ successfully convicted the former Comptroller General of Ecuador and the former Finance Minister of Mozambique following lengthy trials in Miami and Brooklyn.[28] In addition, DOJ obtained trial convictions in two cases involving former commodities trading executives Javier Aguilar and Glenn Oztemel.[29] Both trials highlighted DOJ’s ability to secure and present the testimony of cooperators who plead guilty and testify against their former coconspirators, providing detailed accounts of the bribery schemes. The Aguilar trial included testimony from 10 cooperating witnesses, including the former officials who were bribed, the intermediaries who facilitated the bribe payments, and others.[30] Given these recent successes, DOJ is likely to remain focused on charging individuals in foreign bribery cases.
In addition, the Foreign Extortion Prevention Act (FEPA) was signed into law in December 2023 and amended in July 2024.[31] The FEPA provides a mechanism for U.S. authorities to prosecute the demand side of foreign corruption, and was amended to clarify key jurisdictional hooks as well as the individuals to whom the FEPA applies, in effect harmonizing the law with the FCPA.[32]
The focus on the FCPA and FEPA signals that anti-corruption enforcement is likely to remain active with the incoming administration. FCPA enforcement remained strong under the last Trump Administration and we would expect continued robust enforcement, though the benefits may be even higher for companies that know how to demonstrate that they had strong compliance programs in place.
Digital Assets
Prosecutions related to giants in the digital asset space continued in 2024. The global cryptocurrency exchange BitMEX, for example, pled guilty in July 2024 to violations of the Bank Secrecy Act by failing to establish, implement and maintain an adequate anti-money laundering program.[33] Furthermore, 18 individuals and entities serving as or at cryptocurrency financial services firms were charged in October 2024 for widespread fraud and manipulation in the cryptocurrency markets.[34] In addition, sentences have been handed down related to the breakdown of the FTX exchange, with founder Sam Bankman-Fried sentenced to 25 years in prison and coconspirator sentences ranging from supervised release to seven and a half years in prison.[35]
Financial Institutions
Anti-money laundering enforcement remained strong, with the 10th largest bank in the U.S. pleading guilty and agreeing to pay over $1.8 billion in penalties as a result of the DOJ’s investigation into violations of the Bank Secrecy Act and money laundering, marking the first time a U.S. bank pled guilty to conspiracy to commit money laundering.[36] The plea agreement evidences the DOJ’s focus on strong compliance programs within the financial institution space.
National Security and Export Controls
In recent years, the DOJ has taken up a renewed focus on national security, sanctions and export controls matters. Beginning in 2022, following Russia’s invasion of Ukraine, the DOJ signaled an increased commitment to sanctions enforcement, referring to it as “the new FCPA” in terms of prioritization.[37] In March 2024, Assistant Attorney General Matthew G. Olsen stated that “the National Security Division [will] now interact with corporations and the business community like never before” in this space.[38] In pursuit of such efforts, the DOJ more than doubled the number of prosecutors working on sanctions, export control, and foreign agent registration cases.[39] In May 2024, the National Security Division issued its first declination, to a company that voluntarily disclosed a former employee’s scheme to illegally export products to China.[40] As part of its decision not to prosecute, the DOJ cited the timely and voluntary self-disclosure, which came only one week after retaining outside counsel to conduct an internal investigation, as well as the lack of a significant threat to national security posed by the activity and the fact that the company made no unlawful gains from the offense.[41] The DOJ also focused on individual prosecutions under the Foreign Agents Registration Act (FARA), bringing charges against a number of individuals, notably including U.S. Senator Robert Menendez, former New York State official Linda Sun and U.S. Congressman Enrique Roberto “Henry” Cuellar in 2024.[42] Under the Trump Administration, national security is expected to remain a DOJ priority.
Key Takeaways
Following the election, enforcement priorities are likely to shift at both the DOJ and SEC. Based on the last Trump Administration and stated policy preferences, we can predict some priorities:
- The SEC will likely return to more traditional, bread and butter cases that involve harm to retail investors, such as accounting and disclosure fraud, misappropriation of funds by investment advisers, market manipulation and insider trading, and offering frauds. On the other hand, there likely will be a decrease in enforcement activity related to ESG, cybersecurity, off-channel communications and crypto, which were a focus of the SEC under Gensler and the Biden Administration.
- The SEC will levy smaller penalties on large entities, and penalties will need to bear a relation to a measurable benefit the entity received from its alleged securities law violations. The SEC will be less likely to pursue novel theories of disgorgement. The returns on cooperation are likely to be even greater than before, with companies that cooperate with investigations and self-remediate standing to benefit more tangibly than in the past.
- The SEC likely will take a less expansive approach to materiality, will focus more on issuer disclosures directly linked to financial results and less on cyber or ESG issues, and will be less likely to pursue aggressive theories and perceived “regulation by enforcement.” With resource constraints likely to continue, the SEC may also shy away from pursuing protracted litigation where they are not assured of success. With the SEC more receptive to the arguments made by public companies and regulated entities, effective, thoughtful advocacy will matter more than ever.
- Under the Trump Administration, some areas of white collar enforcement will continue as priorities or even increase, while others will decline. There is likely to remain a strong focus on FCPA enforcement, which increased during the first Trump Administration. In addition, there is likely to be a continued focus on national security and sanctions/export controls, another area that showed significant activity during the previous Trump Administration. On the other hand, there may be decreased activity in traditional business crimes and in the environmental space. There also likely will be lower penalties and fewer monitorships going forward.
- Most DOJ policies are likely to remain in place, including with respect to corporate compliance and cooperation. Indeed, there may be more potential for reduced penalties or declinations for companies that can point to effective compliance programs, internal investigations and self-remediation in the wake of alleged misconduct. As such, companies should pay particular attention to the state of their compliance programs and ensure that they have engaged in periodic assessments and evaluations of their overall effectiveness, with an emphasis on internal reporting mechanisms, regularly updated trainings and the efficient processing and prioritization of whistleblower complaints. Furthermore, companies should invest in the use of new technologies, as well as data and data analytics tools to enhance their compliance programs, as well as ensure that adequate safeguards are in place to monitor those new technologies.
[1] SEC Press Release, “SEC Announces Enforcement Results for Fiscal Year 2024,” (November 22, 2024), available here (SEC Year in Review).
[2] Id.; SEC Press Release, “Terraform and Kwon to Pay $4.5 Billion Following Fraud Verdict,” (July 2, 2024), available here.
[3] SEC Year in Review, supra note 1.
[4] Id.
[5] SEC Press Release, “SEC Files 13 Charges Against Binance Entities and Founder Changpeng Zhao,” (June 5, 2023), available here; SEC Press release, “SEC Charges Coinbase for Operating as an Unregistered Securities Exchange, Broker, and Clearing Agency,” (June 6, 2023), available here; SEC Press Release, “SEC Charges Kraken for Operating as an Unregistered Securities Exchange, Broker, Dealer, and Clearing Agency,” (November 21, 2023), available here.
[6] This approach was first devised by the court in 2023 in an SEC litigation against crypto and blockchain technology company, Ripple Labs Inc., its CEO Brad Garlinghouse and its former CEO and Executive Chairman Christian Larsen. For more information on Cleary Gottlieb’s representation of Ripple Labs Inc. CEO Brad Garlinghouse, see our October 2023 blog post available here.
[7] SEC Year in Review, supra note 1.
[8] SEC Statement, “A Catalyst: Statement on Qatalyst Partners LP,” (September 24, 2024), available here.
[9] SEC Statement, “Cybersecurity Disclosure,” (December 14, 2023), available here.
[10] For more information on the SDNY Court’s Dismissal of SEC Claims Against SolarWinds and CISO, see our July blog post available here.
[11] The Republican commissioners also dissented from four cases brought in the Fall, which claimed that IT companies victimized by the SolarWinds cyber intrusion had misleadingly downplayed the incident in their disclosures.
[12] DOJ Press Release, “Attorney General Merrick B. Garland Designates Jonathan Mayer to Serve as the Justice Department’s First Chief Science and Technology Advisor and Chief AI Officer,” (February 22, 2024), available here.
[13] This was the case in the prior Trump Administration, where, for example, they withdrew the Yates Memo, which focused on individual accountability for corporate misconduct, as well as revised the guidance on monitorships to clarify that the DOJ would appoint a monitor in connection with a resolution only in limited circumstances where there was a “demonstrable need.”
[14] Justice Manual §§ 9-28.900(A)(3)(a)(i), 9-28.900(B); §§ 703.300, 9.28.900(A)(3)(c) (March 2024).
[15] For more information on the Safe Harbor, see our March blog post available here.
[16] The program applies broadly to all corporate misconduct, but specifically identifies certain high priority enforcement areas, including schemes involving financial institutions and the integrity of financial markets; FCPA and FEPA; health care fraud and kickback schemes; federal contract fraud schemes; and domestic corruption schemes. Certain exclusions apply, such as for a tipster who was a CEO, a CFO, or a leader of the scheme; where the tipster has a prior fraud conviction; or where the offense involves crimes of violence. DOJ, “The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals” (April 15, 2024), available here.
[17] Id. at 2-3.
[18] DOJ Blogpost, “Criminal Division’s Voluntary Self-Disclosures Pilot Program for Individuals” (April 22, 2024), available here.
[19] The amount of the awards will be based on the “net proceeds forfeited,” which is the value of forfeited assets remaining after compensating victims and paying other costs associated with the forfeiture. Eligible whistleblowers may receive up to 30% of the first $100 million in net proceeds forfeited, and up to 5% of any net proceeds forfeited between $100 million and $500 million. DOJ Fact Sheet, “U.S. Department of Justice Corporate Whistleblower Awards Pilot Program” (August 1, 2024), available here.
[20] DOJ Temporary Amendment, “Department of Justice Temporary Amendment to Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy” (August 1, 2024), available here.
[21] Argentieri Speech, “Principal Deputy Assistant Attorney General Nicole M. Argentieri Delivers Remarks at the Society of Corporate Compliance and Ethics 23rd Annual Compliance & Ethics Institute,” (September 23, 2024), available here.
[22] DOJ, “The U.S. Department of Justice Criminal Division Evaluation of Corporate Compliance Programs” (September 23, 2024), available here.
[23] Id.
[24] Id.
[25] Related Enforcement Actions: 2024, U.S. DEP’T of JUSTICE, available here.; In re: Boston Consulting Group, Inc. (CEP Declination Letter) (August 27, 2024), available here.
[26] Id.
[27] DOJ Press Release, “Swiss Commodities Trading Company Please Guilty to Foreign Bribery Scheme,” (Mar. 28, 2024), available here; DOJ Press Release, “Commodities Trading Company Will Pay Over $661M to Resolve Foreign Bribery Case,” (March 1, 2024), available here; DOJ Press Release, “SAP to Pay Over $220M to Resolve Foreign Bribery Investigations,” (January 10, 2024), available here.
[28] DOJ Press Release, “Former Comptroller General of Ecuador Sentenced in International Bribery and Money Laundering Scheme,” (October 1, 2024), available here; DOJ Press Release, “Former Finance Minister of Mozambique Convicted of $2B Fraud and Money Laundering Scheme,” (August 8, 2024), available here.
[29] DOJ Press Release, “Oil and Gas Trader Convicted for Role in Foreign Bribery and Money Laundering Scheme,” (February 23, 2024), available here; Press Release, “Former Connecticut-Based Energy Trader Convicted of International Bribery Scheme,” (September 26, 2024), available here.
[30] DOJ Press Release, “Ex-Energy Trader for Vitol Convicted of Foreign Bribery and Money Laundering Scheme,” (February 23, 2024), available here.
[31] U.S. Congress Bill, “Foreign Extortion Prevention Technical Corrections Act”, S. 4548, 118th Cong. (2023), available here.
[32] Id.
[33] DOJ Press Release, “Global Cryptocurrency Exchange BitMEX Pleads Guilty To Bank Secrecy Act Offense,” (July 10, 2024), available here.
[34] DOJ Press Release, “Eighteen Individuals and Entities Charged in International Operation Targeting Widespread Fraud and Manipulation in the Cryptocurrency Markets,” (October 9, 2024), available here.
[35] DOJ Press Release, “Samuel Bankman-Fried Sentenced to 25 Years for His Orchestration of Multiple Fraudulent Schemes” (March 28, 2024), available here; Reuters, “Bankman-Fried’s ex-deputy Wang avoids prison time over crypto fraud,” Reuters, (November 20, 2024), available here; DOJ Press Release, “Former FTX Executive Ryan Salame Sentenced to 90 Months in Prison,” (May 28, 2024), available here.
[36] DOJ Press Release, “TD Bank Pleads Guilty to Bank Secrecy Act and Money Laundering Conspiracy Violations in $1.8B Resolution,” (October 10, 2024), available here.
[37] Monaco Speech, “Deputy Attorney General Lisa O. Monaco Delivers Keynote Remarks at 2022 GIR Live: Women in Investigations,” (June 16, 2022), available here.
[38] Olsen Speech, “Assistant Attorney General Matthew G. Olsen Delivers Keynote Speech at the American Bar Association’s 39th National Institute on White Collar Crime,” (March 8, 2024), available here.
[39] Id.
[40] In re Sigma-Aldrich, Inc., d/b/a MilliporeSigma, (Declination) (May 14, 2024), available here.
[41] Id.
[42] DOJ, Foreign Agents Registration Act: Recent Cases, available here.