Author Archives: ads9053

The GENIUS Act: A New Era of Stablecoin Regulation

by Jeffrey Steiner, Jason Cabral, Ro Spaziani, and Sara Weed

Left to Right: Jeffrey Steiner, Jason Cabral, Ro Spaziani, and Sara Weed (Photos courtesy of the authors)

The Act is the most significant United States law affecting the digital assets industry to date and reflects the Administration’s and Congress’ priorities of establishing a comprehensive framework for the United States’ approach to digital assets and related activities.

On July 18, 2025, the President signed the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the GENIUS Act or the Act) into law. The GENIUS Act is the most significant United States law affecting the digital assets industry to date and reflects the Administration’s and Congress’ priorities of establishing a comprehensive framework for the United States’ approach to digital assets and related activities. The legislation, which benefited from strong bipartisan support, was adopted on June 17, 2025 in the U.S. Senate by a vote of 68 to 30, and in the U.S. House of Representatives by a vote of 308 to 122, on July 17, 2025.

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Changes in Approach to Criminal Liability: Trump’s Executive Order Regarding Criminal Regulatory Offenses

by Greg L. Johnson, Clare M. Bienvenu, Sean Toomey, and Colin North

Greg L. Johnson, Clare M. Bienvenu, Sean Toomey & Colin North (photos courtesy of the authors)

On May 9, 2025, the Trump Administration published an executive order (“EO”), titled “Fighting Overcriminalization in Federal Regulations,” that targets criminal regulatory offenses subject to strict liability, or liability that attaches without a required criminal mindset. The EO states that strict liability offenses are “generally disfavored,” and encourages agencies to consider civil or administrative, rather than criminal, enforcement of strict liability offenses. The EO further explains that prosecution of criminal regulatory offenses is “most appropriate” when “a putative defendant is alleged to have known his conduct was unlawful.”

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Monetary Authority of Singapore Imposes Financial Penalties, Prohibition Orders, and Reprimands for Anti-Money Laundering Breaches

by Jonathan J. Rusch

Jonathan J. Rusch (photo courtesy of the author)

Since 2023, when Singapore Police arrested 10 people connected with Singapore’s largest-ever case of money laundering (involving S$3 billion in cash and assets)[1], the Monetary Authority of Singapore (MAS) has been conducting supervisory examinations against pertinent financial institutions with a nexus to persons of interest in that case and certain employees of those financial institutions.

On July 4, the MAS announced regulatory actions against nine financial institutions and prohibition orders and reprimands against 18 executives and managers of those institutions for failure to comply with MAS’s Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) requirements.[2] This post will summarize those actions and identify certain lessons to be learned for AML/CFT compliance.

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The Trust Paradox: How Aggressive Whistleblower Enforcement Risks Undermining Compliance Culture

by Sharon Oded

Sharon Oded (photo courtesy of the author)

In the evolving landscape of corporate regulation, whistleblower frameworks have emerged as indispensable instruments for surfacing misconduct that might otherwise remain obscured. From financial fraud to sanctions violations, whistleblower disclosures have catalyzed some of the most significant enforcement actions of the past decade. Yet, as enforcement agencies increasingly adopt aggressive, incentive-driven approaches, a critical inflection point has been reached: Are we inadvertently undermining the very cultures of integrity we seek to cultivate?

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The AI Whistleblower Protection Act Is Critical for Enhancing Corporate Compliance

by Stephen M. Kohn and Sophie Luskin

Stephen Kohn and Sophie Luskin (photos courtesy of authors)

On May 15, 2025, Senator Charles Grassley (R-IA) introduced the bipartisan AI Whistleblower Protection Act (AIWPA). Co-sponsored by senators Chris Coons (D-DE), Marsha Blackburn (R-TN), Amy Klobuchar (D-MN), Josh Hawley (R-MO) and Brian Schatz (D-HI), it creates clear channels for AI industry employees to make lawful disclosures about safety issues with protections from retaliation.

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A Reflection on the OECD’s Report (Part II): Governments’ Assessments of Corporate Anti-Corruption Compliance

by Veronica Root Martinez and Liz Carrasco

Left to right: Veronica Root Martinez and Liz Carrasco (photos courtesy of authors)

Governments have a responsibility to evaluate corporate compliance programs and an opportunity to design strong regulatory frameworks. To identify reforms and encourage implementation, they must first understand the state of compliance. The Organisation for Economic Cooperation and Development (OECD) report Governments’ Assessments of Corporate Anti-Corruption Compliance[1] provides a detailed look at how governments are approaching the assessment of corporate anti-corruption compliance programs. The report explains that clear, consistent standards for assessing these programs would improve both efficiency and credibility—but few governments have adopted such standards. This blog post explores governments’ roles in 1) guiding companies on compliance criteria, 2) enhancing oversight, and 3) the value of information sharing.

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Board Priorities in a Geopolitical Landscape: Risk, Compliance, and Supply Chain Resilience

This post comes from a webinar with Bets Lillo, Edward Knight, Will A. Clarke, and Jana del-Cerro delivered on May 22, 2025. They offered a clear-eyed view of how boards and executive management must adapt to effectively lead amid a world where national security, economic policy, and supply chain resilience are deeply intertwined. Five key takeaways from their discussion are outlined below, alongside practical implications for boardroom oversight and planning.

From left to right: Bets Lillo, Edward Knight, Will A. Clarke, and Jana del-Cerro (photos courtesy of authors).

As the impact of global interdependencies becomes increasingly complex, boards and executive management are guiding and governing their companies in an unpredictable environment. That was the central theme of the recent May 2025 webinar, Geopolitical Issues Impacting Global Supply Chains and National Security, hosted by the Nasdaq Center for Board Excellence and the Program on Corporate Compliance and Enforcement at NYU School of Law.

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A Reflection on the OECD’s Report (Part I): Companies’ Assessments of Anti-Corruption Compliance

by Veronica Root Martinez and Liz Carrasco

Left to right: Veronica Root Martinez and Liz Carrasco (photos courtesy of authors)

As anti-corruption compliance programs have become standard within corporations, an increasing number of companies are shifting their focus to the effectiveness of these programs. The Organisation for Economic Cooperation and Development (OECD) report Companies’ Assessments of Anti-Corruption Compliance[1] provides a detailed look at this shift within the private sector. Drawing on survey data and examples from a range of companies, the report highlights a growing recognition that compliance cannot be isolated from a company’s culture, leadership, or structure. In short, the question is not merely whether a compliance program exists, but whether it is effective.

The report includes anonymized company case studies to illustrate various approaches and insights. This blog post explores three key aspects of the report: (1) why companies assess the effectiveness of their anti-corruption compliance programs; (2) what methodologies they use to do so; (3) the tools companies leverage to monitor progress over time.

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