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Client Alert July 24, 2019

China’s Belt and Road Initiative Could Lead to a Trail of Global Corruption Investigations

  • For those considering investing in projects tied to China’s Belt and Road Initiative (BRI), corruption and bribery are major areas of concern.
  • In the event of fraud or misconduct allegations, parties and their counsel will need to understand and anticipate how global anti-corruption enforcers might approach such investigations.
  • Carrying out a series of “stress tests” or appointing an independent third-party examiner are two examples of proactive measures companies can take to mitigate the risk of being on the wrong end of an anti-corruption investigation.

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Client Alert March 27, 2019

Successfully Fighting a Spoofing or Market Manipulation Subpoena from the DOJ or the CFTC

  • The U.S. government has set its sights on market manipulation and “spoofing” among both traditional and digital currency traders.
  • For the trading firms and other market participants who could be in the government’s crosshairs, now is the time to plan how you will respond to a subpoena.
  • Traders and trading firms that find themselves on the receiving end of a subpoena related to spoofing or market manipulation should not immediately assume that cooperation is the best or only way to respond.

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