CFTC Penalizes Registrant for Outsourced IT Security Lapses Last month, the CFTC settled charges against an organization for its failure to ensure the security of its’ customers’ records and information. The registrant’s third-party vendor gained unauthorized access to more than 90,000 records, and the CFTC’s charges make clear the risks registrants can face when their third parties are derelict in their duties....

Google Ordered to Surrender Foreign Server Data Attorneys from Bracewell analyze a recent court decision ordering Google to comply with warrants issued and produce to the FBI data that was stored on servers abroad. The decision could have far-reaching implications and has the potential to impact any company storing data overseas – or considering it. with co-author Laura Prebeck Hang On August 17,...

Nationwide Prosecutions: "Just the Beginning" Recent DOJ and Department of Health and Human Services charges were brought against 412 defendants, across 30+ states, with defendants accused of defrauding taxpayers of approximately $1.3 billion. It’s been described as the largest health care fraud enforcement action in DOJ history. In light of the varied health-care-related business practices that are the subjects of the major...

Your Integrity Policy Matters Mexico’s General Law of Administrative Accountability, set to go into effect next week, is the final part of a historic package of far-reaching anti-corruption laws, dubbed the National Anti-Corruption System, that were passed last year. Taken as a whole, the National Anti-Corruption System will have far-flung consequences for those doing business in Mexico and will expand the scope...

Bracewell white collar attorneys dissect guidance from the DOJ’s Fraud Section on how it assesses compliance program (and intends to). This guidance provides insight into the questions corporate counsel should expect from DOJ prosecutors during a criminal investigation and highlights common indicators of a strong corporate culture of compliance.

Case Highlights Growing Trend in Collaborative Enforcement This article by Bracewell white-collar attorneys details the resolution of parallel investigations by U.S., U.K. and Brazilian authorities. Rolls-Royce’s long-running scheme to bribe government officials across the globe in exchange for government contracts has resulted in a record enforcement action. Learn about what this could mean for future investigations. By: Phil Bezanson, Glen Kopp and...

A recent Washington state Supreme Court adopted a rarely affirmed position and held that attorney-client privilege does not extend to postemployment communications between former employees and counsel representing the former employer. This ruling would impact counsel responsible for conducting internal investigations and could restrict their ability to interview their clients’ former employees.