White Collar Watch: March 2017 (Vol. I, Issue 1)

White Collar Watch

To view the March 2017 edition of Blank Rome's White Collar Watch, please click here.

Welcome to the inaugural edition of White Collar Watch, a relaunch of Blank Rome’s White Collar Defense & Investigations group quarterly newsletter.


Blank Rome’s White Collar Defense & Investigations practice group is comprised of seasoned, nationally recognized attorneys who represent companies and individuals facing criminal and regulatory investigations, congressional inquiries, whistleblower accusations, or self-discovered misconduct. With the relaunch of this quarterly newsletter, our team of white collar attorneys will discuss key industry topics and provide insightful analysis on a wide range of practical issues potentially affecting companies and individuals within numerous industries.

Authored by members of our team, many of whom are former prosecutors, this inaugural edition features articles on the Foreign Corrupt Practices Act, the “FinTech” industry, Department of Justice compliance updates, and the impact of IRS tax liens on passport revocations.

We welcome your feedback, as well as any suggestions for articles in areas that may impact your business, and encourage you to share this newsletter with friends and colleagues whom you think may find it useful. Our White Collar Defense & Investigations practice group is here to be of service to you, and your companies, in every way possible. 

With warm regards,

Joseph G. PolukaInbal Paz Garrity, and William B. Shields
Editors, White Collar Watch


New York Department of Financial Services Implements New “First-in-the-Nation” Cybersecurity Regulations
by Inbal Paz Garrity and Nicholas R. Tambone

As of March 1, 2017, New York financial institutions subject to the oversight of the New York Department of Financial Services (“DFS”) are required to comply with a new cybersecurity regulatory scheme. Compliance deadlines for certain measures are coming as early as August 28, 2017. Affected financial institutions should take action now to ensure timely compliance.

U.S. Department of Justice Issues New Guidance on Corporate Compliance Programs
by Shawn M. Wright, Carlos F. Ortiz, and Nicholas R. Tambone

The U.S. Department of Justice (“DOJ”) Criminal Division, Fraud Section, recently published new guidance on corporate compliance programs. All corporate counsel, officers, and directors should be aware of this guidance, and corporate compliance professionals should ensure not only that compliance policies follow this guidance, but that actual practices also meet the expectations outlined by the DOJ.

The Global Anti-Corruption Corner: A Primer to the Foreign Corrupt Practices Act
by Shawn M. Wright, Carlos F. Ortiz, Mayling C. Blanco, and Ariel S. Glasner

Any company doing business abroad is subject to the long reach of the Foreign Corrupt Practices Act (“FCPA”). Small or privately held companies, just like large or public companies, are subject to the criminal specter of the FCPA. The operative inquiry is whether the company is operating and/or transacting any type of business abroad with the government, government-owned entities, or involving foreign officials—either directly, through joint ventures, or indirectly, through agents. A foreign official also includes employees of entities owned by the government.

The FinTech Revolution: An Introduction to Financial Technology
by Ariel S. Glasner and Bridget Briggs

“FinTech” has become a buzz word of the decade. The term, which is a moniker for “financial technology,” captures all manner of technological innovation in personal and commercial finance; innovations that are increasingly gaining the attention of regulators seeking to prevent money laundering and financial frauds. FinTech includes applications that support and enable financial and banking services, such as mobile banking apps, credit card strip readers that attach to mobile devices and tablets, and software that allows companies to process payments from customers.

IRS Announces Plans to Move Forward with Passport Revocation Program
by Jed M. Silversmith and Jeffrey M. Rosenfeld

U.S. citizens who owe more than $50,000 in unpaid federal taxes are at substantial risk of having their U.S. passports revoked within the next few months and should contact counsel for help with reaching an immediate resolution with the Internal Revenue Service ("IRS"). Citizens living abroad should also be aware that they may be forced to return to the United States until they resolve their tax debts.


The Blank Rome White Collar Defense & Investigations group is proud to announce the promotion of Mayling C. Blanco to partner.

Ms. Blanco represents corporations and individuals in white collar defense, government investigations, and commercial litigation matters, notably concentrating her practice on the Foreign Corrupt Practices Act and corporate fraud, as well as matters implicating criminal tax exposure. She has conducted domestic and international, multijurisdictional investigations for clients with ventures in Latin America, Asia, and Europe, and has represented her clients before the U.S. Department of Justice’s Criminal, Civil, and Tax Divisions. She also advises corporations and financial institutions in connection with corporate governance and compliance matters. In litigation, Ms. Blanco has experience before various Federal District Courts, U.S. Tax Court, the Superior Court of New Jersey, the New Jersey Appellate Division, and the New Jersey Supreme Court, defending clients in white collar, tax, commercial, employment, and constitutional matters. She is a member of the Seton Hall Alumni Council, the Firm’s Diversity Committee, and active with the Hispanic National Bar Association and the New Jersey Hispanic Bar Association. She practices in Blank Rome’s New York and Princeton, N.J. offices. You may reach Ms. Blanco at


Joseph G. Poluka:
The Pendulum Has Swung: Off-Label Use and a New World Order at the American Conference Institute’s 29th FDA Boot Camp, March 24, 2017, in New York, NY.

Mayling C. Blanco:
Corruption in the GlobalGateway: Developments and Enforcement Trends Under the FCPA and Other Anti-Bribery Laws at the Hispanic National Bar Association Corporate Counsel Conference & Moot Court Competition, March 31, 2017, in Miami, FL.

Carlos F. Ortiz and Mayling C. Blanco:
Hot topics – Criminal Tax Enforcement at the 2017 New Jersey State Bar Association Annual Meeting, May 17-19, 2017, in Atlantic City, NJ.

To learn more about Blank Rome's White Collar Defense & Investigations group, visit

© 2017 Blank Rome LLP. All rights reserved. Please contact Blank Rome for permission to reprint. Notice: The purpose of this update is to identify select developments that may be of interest to readers. The information contained herein is abridged and summarized from various sources, the accuracy and completeness of which cannot be assured. This update should not be construed as legal advice or opinion, and is not a substitute for the advice of counsel.