The Capital Commitment

Proskauer on Private Fund Litigation

Tag Archives: department of justice

Bloomberg Law: White Collar Crime Investigation & the Biden Administration

As part of an ongoing series of articles that focus on the top regulatory and litigation risks for private funds in 2021, William C. Komaroff, Seetha Ramachandran and Joseph Hartunian write for Bloomberg Law on the return to civil and criminal collaboration in white collar investigations under the Biden Administration. Read the full article here.… Continue Reading

Return to Civil and Criminal Collaboration in White Collar under Biden Administration

Under the Biden Administration, we expect the Department of Justice to reinvigorate the policies aimed at increasing coordination between the criminal and civil divisions.  In a 2015 Memorandum – the “Yates Memo” – former Deputy Attorney General Sally Yates pushed for “early and regular communication” between civil and criminal division attorneys in their pursuit of … Continue Reading

FinCEN’s $390 Million case against Capital One – And What it Means for AML Enforcement

As the financial services industry prepares for expanded criminal and civil enforcement under the Bank Secrecy Act (“BSA”) with the passage of the Anti-Money Laundering Act of 2020, FinCEN’s recent case against Capital One shows how FinCEN’s approach to AML enforcement is evolving.… Continue Reading

FinCEN Explains What Guides Its Enforcement Decisions

On August 18, 2020, the Financial Crimes Enforcement Network (FinCEN), which is the primary regulator and administrator of the Bank Secrecy Act (BSA), issued a statement on enforcement of the BSA. The requirements of the BSA typically apply to financial institutions, but in certain circumstances the Act applies to nonfinancial businesses and individuals.… Continue Reading
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