Overview
On November 9, 2022 Law360 published an article by Nicholas Silverman and James Purce titled "JPMorgan RICO Case Should Inspire Proactive Compliance.” The article discusses United States v. Smith, No. 19-cr-669. It summarizes the allegations in Smith and discusses the need for companies to engage in proactive compliance efforts.
In the piece the authors write, "Companies should continue to be proactive on topics of interest for enforcement agencies and DOJ and assume that deviation from industry standards and best practices might form the basis of even criminal liability. Right now, the wave of anti-spoofing litigation is on the decline and sophisticated companies are well aware of the prohibition against spoofing. Those companies should monitor enforcement agencies' public statements to stay abreast of the next enforcement priority and take proactive action to avoid getting swept up in an enforcement action."
