Compliance Hot Spots: 'Endemic Problem' at SEC | Greenberg Traurig Snags Mueller Lawyer | Amazon Will Seek PI in Cloud Case | FDA Warns of 'Unprecedented' Discovery Demand
Welcome to Compliance Hot Spots, our weekly Law.com briefing on white-collar, regulatory and compliance. We're looking today at whistleblower delays at the SEC, and scroll down for Who Got the Work, all the new moves and much more. Thanks, always, for reading!
January 14, 2020 at 09:00 PM
8 minute read
Welcome to Compliance Hot Spots, our white-collar, regulatory and compliance Law.com briefing. We're catching up on some whistleblower issues at the SEC, and scroll down for big headlines, Who Got the Work and a roundup of recent notable moves.
Tips, feedback and general thoughts on your practices are always appreciated. I'm C. Ryan Barber in Washington, and you can reach me at [email protected] and 202-828-0315. Follow me on Twitter @cryanbarber.
An 'Endemic Problem' at the SEC
It has been the mixed blessing of the U.S. Securities and Exchange Commission's whistleblower program: With more awareness and popularity has come more tips—and longer waits for awards.
Sean McKessy, a Phillips & Cohen partner who served as the first chief of the SEC's whistleblower program, this week described the commission's delays in processing award applications as an "endemic problem" that "may impede the progress and the credibility of the program to its detriment."
As the SEC considers changes to streamline the review process, Gibson, Dunn & Crutcher partner F. Joseph Warin said he has observed a "marked focus on speed" in the past year in cases where the SEC's evidence suggests that the commission has help from a whistleblower.
"In several matters where we know that there is a whistleblower, we hear the senior leadership of the [enforcement] staff saying we need to move this along," Warin said Monday on a webcast the firm hosted.
That approach, Warin said, has involved a departure from the traditional path of starting with the lowest-ranking employees of a company and working up to the C-suite. The SEC has instead conducted "very targeted testimonial sessions" to determine whether to bring a case or not.
"It's apparent the message has come down," Warin said, of the pressure to pick up the pace in cases involving whistleblowers.
"It does seem," he added, "that there is a keen focus on speed.
Who Got the Work
>> A team from Akin Gump Strauss Hauer & Feld has registered to lobby for Buccaneers Holdings LLC on Telephone Consumer Protection Act policies. The team includes Hunter Bates, former chief of staff to Sen. Mitch McConnell from 2000 to 2002.
>> Lawyers from Clark Hill, including Leigh Roadman and Mason Floyd, are advising a businessman and his company in an emergency SEC enforcement action. The agency said it obtained an asset freeze in connection to an alleged "Ponzi-like scheme" that raised $75 million.
Compliance Reading Corner
Courts and cases
Landmark Facebook Settlement Still Working Its Way Through Court. "Judge Timothy Kelly of the U.S. District Court for the District of Columbia has ordered Facebook and the government to file by Jan. 24 written responses to privacy advocacy groups critical of the settlement." [WSJ]
Amazon Will Ask a Court to Block Microsoft from Working on a $10 Billion Cloud Computing Contract. "Amazon will ask a federal court to temporarily block Microsoft from working on a $10 billion cloud computing contract for the military, according to a court filing Monday. Microsoft is scheduled to begin its work on the contract on Feb. 11. But Amazon's cloud computing division will seek a preliminary injunction to "prevent the issuance of substantive task orders under the contract," the filing said. Amazon's request will be submitted by Jan. 24." [CNN] More here at Bloomberg.
Compliance monitors
Winston & Strawn Partner Pam Davis on FCPA Monitors. "It boils down to—do they trust that this company has the ability to prevent a future FCPA problem? Has the company put in a compliance program that is effective and secure and that can prevent future violations? Do the members of the board and the senior leadership of the company look at this as something that is critical and important?" [Corporate Crime Reporter]
How To Avoid and 'Survive' the Dreaded Monitorship. "The DOJ and other government agencies continue to use monitors in corporate resolutions. By staying abreast of changes in DOJ guidance on monitorships and corporate compliance programs, companies can aid their own efforts to successfully navigate settlement discussions with the DOJ and other enforcement agencies and (hopefully) avoid a monitorship altogether," lawyers from Eversheds Sutherland write. [New York Law Journal]
Effective Monitoring of Compliance Programs: A Guide for Practitioners. "The U.S. Department of Justice (DOJ) emphasized the importance of periodic testing and ensuring that compliance programs 'work in practice' in its 2019 guidance document evaluation of corporate compliance programs. Despite this mandate to companies, enforcement agencies have neither outlined criteria for best-in-class compliance monitoring systems nor provided practical guidance as to how practitioners should test their effectiveness." [Corporate Counsel]
Inside the Ethics and Compliance Program at Milliken: A Q&A With General Counsel Debra Clements. "Our ethics and compliance program continues to innovate in order to drive corporate accountability, transparency and progress on issues of corporate social responsibility, or corporate sustainability. Our program collaborates with our business leadership to support our sustainability goals, including Milliken's commitment to convening thought leaders to advance end-of-life solutions on plastics." [Law.com]
Federal agencies
FDA's Top Lawyer Says Theranos Case Places 'Unprecedented' Discovery Strain on Agency. The top lawyer at the U.S. Food and Drug Administration told the judge overseeing the criminal case against Theranos founder Elizabeth Holmes (at left) that the case is putting "wholly unprecedented" demands on the agency to fulfill a court order to hand over internal agency documents to the defense team. [Law.com]
Treasury Department Unveils New Rules for Foreign Investors in U.S. Businesses. "The Treasury Department unveiled rules on Monday designed to increase scrutiny of foreign investors whose potential stakes in U.S. businesses could pose a national security threat." [WSJ]
Senator Whose Spouse Runs Major Exchange to Help Oversee Regulator. "A new U.S. senator whose spouse both runs and owns a minority stake in a major exchange operator will help oversee one of the company's main federal regulators, setting up a potential conflict of interest. Republican leadership assigned interim Sen. Kelly Loeffler (R., Ga.), whose husband, Jeffrey Sprecher, is chairman and chief executive of Intercontinental Exchange Inc., to serve on the Senate Agriculture Committee." [WSJ]
Notable Moves & Announcements
>> Greenberg Traurig has hired former Justice Department lawyer Kyle Freeny (at left), who served on the Mueller prosecution team, as a shareholder in Washington. "I was drawn to the firm's reputation and the strong white-collar practice," Freeny said in a statement. "As the government continues to expand its jurisdictional reach, Greenberg Traurig is laser focused on preparing companies and individuals for this new regulatory climate." Freeny was among nearly two dozen prosecutors who worked on the Russia investigation.
>> Former Deputy Attorney General Rod Rosenstein is joining King & Spalding in Washington, D.C., as an equity partner, marking the latest addition of former top Justice Department brass at the firm.
>> Leandra English, a former deputy director of the Consumer Financial Protection Bureau, was named Tuesday as a top adviser to Linda Lacewell, superintendent of the New York Department of Financial Services. English will manage and develop policy initiatives, DFS said in a statement. "Leandra is a fierce consumer advocate with extensive experience in leadership positions across the federal government," Lacewell said.
>> Matt Miner, a top U.S. Justice Department official who played a key role developing policies for white-collar enforcement under the Trump administration, is returning later this month to his former law firm, Morgan, Lewis & Bockius.
>> Shaun Wu has left Kobre & Kim to join Paul Hastings as a partner in the firm's white-collar defense practice. Based in Asia, Wu focuses on compliance reviews involving China and on advising clients in fraud and FCPA investigations. "Investing significantly in our leading Investigations and White Collar Defense practice across Asia, Europe, Latin American and the United States continues to be a focus for us," Paul Hastings chairman Seth Zachary said.
>> Crowell & Moring has hired Andrew Pruitt as a litigation partner in Washington. Pruitt was formerly a partner at Kirkland & Ellis.
>> Covington & Burling associate Chase Johnson will be the Trump administration's pick for inspector general at the FCC. Johnson practices in the commercial litigation and government contracts groups. David Hunt has served as inspector general since 2011. He first joined the inspector's office in 2006.
>> "Holland & Knight has hired Brian Hayes, a former FBI special agent who headed the criminal division of Chicago's U.S. attorney's office," Bloomberg Law reports.
>> Greenberg Traurig said Smith W. Davis has joined the firm as a shareholder in Washington from Akin Gump Strauss Hauer & Feld. Davis, a former counsel to the U.S. House of Representatives Judiciary Committee, will focus on government law and policy Practice.
>> "Former Sen. Norm Coleman (R-Minn.) is leaving his role as the leader of Hogan Lovells' Government Relations and Public Affairs practice and will be replaced by Ivan Zapien, the firm announced on Friday," according to The Hill. Zapien has been a Hogan Lovells partner since 2017.
>> Morgan Lewis has hired Heather Sears as of counsel in Washington. Sears formerly was legal counsel at Alpha Omega Consulting Group LLC and president of Global Compliance Counsel.
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Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
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