ProfessionalsRichard C. Tarlowe

Richard C. Tarlowe
Partner
Tel: +1-212-373-3035
Fax: +1-212-492-0035
emailrtarlowe@paulweiss.com
1285 Avenue of the Americas
New York,
NY
10019-6064
Fax: +1-212-492-0035
Richard Tarlowe, a former federal prosecutor and a partner in the Litigation Department, focuses his practice on white collar and regulatory defense, government investigations, and high-stakes litigation. Richard regularly counsels corporations, boards and senior executives in internal investigations and in all stages of criminal and regulatory investigations and proceedings.
EXPERIENCE
Prior to joining Paul, Weiss, Richard served as an Assistant U.S. Attorney in the Southern District of New York, where he was Chief of the Complex Frauds and Cybercrime Unit and a member of its Securities & Commodities Fraud Task Force. Richard led and oversaw the investigation and prosecution of a wide array of white collar matters, including accounting fraud, insider trading, market manipulation and other sophisticated financial frauds, cybercrimes, public corruption, Foreign Corrupt Practices Act (FCPA) violations, criminal tax offenses and healthcare fraud.
Since leaving government service in 2015, Richard has represented a wide variety of clients, including corporations, boards of directors, senior executives and other prominent individuals, in some of the nation’s highest-profile and most sensitive criminal and regulatory matters. Some of Richard’s notable recent representations include:
- Leon Cooperman and Omega Advisors in an insider trading lawsuit brought by the SEC – the case was settled on a no-admit no-deny basis with no industry bar;
- a former senior government official and cabinet member in connection with a DOJ Inspector General review and Congressional investigations relating to the 2016 Presidential election;
- one of the world’s largest technology companies and several executives in connection with an SEC investigation relating to accounting and financial reporting issues – the investigation was terminated without any enforcement action;
- a founder and CEO of multi-billion-dollar hedge fund in a criminal securities fraud trial relating to allegations of mismarking of residential mortgage-backed securities;
- a former Chairman and CEO of a public company in connection with parallel criminal and SEC investigations concerning accounting and financial reporting issues;
- The National Football League in connection with the administration of its landmark concussion litigation class action settlement;
- The Philadelphia 76ers in an internal investigation relating to the use of certain anonymous Twitter accounts to post information concerning the club, its personnel and related topics;
- a leading private equity firm in connection with two SEC investigations relating to certain trading activities – the investigations were both terminated without any enforcement action;
- a leading private equity firm in connection with parallel DOJ and SEC investigations concerning financial reporting and disclosures by one of its portfolio companies;
- a multi-billion dollar hedge fund in connection with an SEC insider trading investigation;
- the board of directors of a public company in connection with an SEC investigation concerning accounting and financial reporting;
- the audit committee of the board of directors of a public company in connection with parallel criminal and SEC investigations of alleged FCPA violations;
- a CEO and prominent philanthropist in connection with a criminal investigation concerning the alleged bribery of a public official;
- a not-for-profit institution in connection with whistleblower allegations; and
- a global financial institution in investigations of its compliance with Bank Secrecy Act/anti-money laundering requirements.
During his eight-year tenure as a federal prosecutor, Richard conducted numerous trials, including some of the most significant and high-profile securities fraud cases in the country, and handled numerous appeals before the U.S. Court of Appeals for the Second Circuit. He also received the Department of Justice Director’s Award for Superior Performance. His matters included:
- U.S. v. Rajat Gupta: co-lead counsel in the investigation and trial of the former Goldman, Sachs director and chair of McKinsey & Co. for insider trading;
- U.S. v. Zvi Goffer, et al.: co-lead counsel in the investigation and trial of proprietary traders who bribed attorneys at international law firm for nonpublic information about mergers and acquisitions; and
- U.S. v. Todd Newman, et al.: co-lead counsel in the investigation and trial of several hedge fund portfolio managers and analysts for insider trading.
Prior to his service as a federal prosecutor, Richard focused on white collar and regulatory defense and internal investigations at a New York City law firm. Richard was named a Rising Star by the New York Law Journal in 2014. He serves as Co-Chair of the UJA White Collar & Securities Enforcement Group.
Related Resources
Lorin Reisner, Richard Tarlowe and Harris Fischman to Participate in DOJ and SEC Enforcement and Litigation Virtual Panel
- Sep 15, 2020
- Events
Lorin Reisner, Richard Tarlowe and Harris Fischman to Participate in DOJ and SEC Enforcement and Litigation Virtual Panel
Litigation partners Lorin Reisner, Richard Tarlowe and Harris Fischman will participate in an upcoming virtual panel, “Hot Trends in DOJ and SEC Enforcement & Litigation,” presented by Sandpiper Partners LLC.
D.C. Circuit Curtails House of Representatives’ Oversight Authority, And Other Developments in Congressional Investigations
- Sep 04, 2020
- Publications
D.C. Circuit Curtails House of Representatives’ Oversight Authority, And Other Developments in Congressional Investigations
The D.C. Circuit recently issued a significant ruling that severely curtails the House of Representatives’ practical power to conduct oversight and investigations.
New York DFS Files First Enforcement Action Alleging Violations of Cybersecurity Regulation
- Jul 30, 2020
- Publications
New York DFS Files First Enforcement Action Alleging Violations of Cybersecurity Regulation
New York’s Department of Financial Services (NY DFS) recently brought its first enforcement action alleging violations of its Part 500 Cybersecurity Regulation. The action alleges that First American Title Insurance Company violated…
Supreme Court Upholds the SEC’s Authority to Seek Disgorgement in Civil Actions, But Imposes Important Limiting Principles
- Jun 25, 2020
- Publications
Supreme Court Upholds the SEC’s Authority to Seek Disgorgement in Civil Actions, But Imposes Important Limiting Principles
The Supreme Court held on June 22 that the SEC may seek disgorgement in enforcement actions, as long as the disgorgement does not exceed a wrongdoer’s net profits and is to be awarded for victims.
DOJ Antitrust Division and SEC Sign Memorandum of Understanding on Cooperation
- Jun 24, 2020
- Publications
DOJ Antitrust Division and SEC Sign Memorandum of Understanding on Cooperation
On June 22, the DOJ’s Antitrust Division and the SEC announced that they have signed a memorandum of understanding to enhance cooperation between the two agencies. Beyond continuing cooperation in rulemaking, investigations and…
DOJ 2020 Guidance for Evaluating Corporate Compliance Incorporates Feedback From Business and Compliance Communities
- Jun 08, 2020
- Publications
DOJ 2020 Guidance for Evaluating Corporate Compliance Incorporates Feedback From Business and Compliance Communities
The DOJ’s Criminal Division released updated guidance regarding the manner in which prosecutors evaluate the effectiveness of corporate compliance programs. The guidance makes clear that companies should continuously update their…
Court Holds that Syndicated Bank Loan Is Not a “Security”
- May 26, 2020
- Publications
Court Holds that Syndicated Bank Loan Is Not a “Security”
Federal and state securities laws generally apply only to instruments that qualify as “securities.” The question of whether a particular instrument is a security, therefore, can have significant and far-reaching consequences. Nearly…
False Claims Act Liability in the Age of COVID-19
- May 19, 2020
- Publications
False Claims Act Liability in the Age of COVID-19
The CARES Act and other COVID-19 relief measures have brought new focus on the False Claims Act, a potent tool used by the government and private whistleblowers for pursuing government fraud claims. This memo provides a primer on the …
DOJ Announces Preliminary Inquiry into Potential Fraud in the Paycheck Protection Program
- May 05, 2020
- Publications
DOJ Announces Preliminary Inquiry into Potential Fraud in the Paycheck Protection Program
A senior DOJ official recently stated publicly that the DOJ has initiated a preliminary inquiry into potential fraud in the CARES Act’s Paycheck Protection Program and has already found possible fraud among businesses seeking relief.
Second Circuit Denies Rehearing in Key Insider Trading Case
- Apr 13, 2020
- Publications
Second Circuit Denies Rehearing in Key Insider Trading Case
In denying defendants’ petition for rehearing in United States v. Blaszczak, the Second Circuit firmly established potential liability for insider trading in the criminal context even where the original “tipper” receives no personal…
White-Collar Enforcement Priorities in the Wake of COVID-19
- Mar 31, 2020
- Publications
White-Collar Enforcement Priorities in the Wake of COVID-19
The DOJ and SEC have signaled an intention to focus on misconduct related specifically to the coronavirus, at least temporarily. Combined with ongoing practical limitations, that focus has slowed down traditional white-collar…
SEC Enforcement Co-Directors Issue Statement on Potential Insider Trading and Selective Disclosure Risks Related to COVID-19
- Mar 25, 2020
- Publications
SEC Enforcement Co-Directors Issue Statement on Potential Insider Trading and Selective Disclosure Risks Related to COVID-19
On March 23, SEC Division of Enforcement Co-Directors Stephanie Avakian and Steven Peikin issued a statement concerning “market integrity” in light of the unprecedented impacts of the COVID-19 pandemic.
COVID-19: A Special Audio Presentation of Our Partners
- Mar 24, 2020
- Videos
COVID-19: A Special Audio Presentation of Our Partners
The Cyberspace Solarium Commission’s Final Report and Recommendations Could Have Implications for Business
- Mar 13, 2020
- Publications
The Cyberspace Solarium Commission’s Final Report and Recommendations Could Have Implications for Business
On March 11, 2020, the Cyberspace Solarium Commission (the “CSC” or the “Commission”)[1] published its Final Report,[2] which is the culmination of nearly a year of work, including approximately 30 meetings and 300 interviews.
Mitigating Cybersecurity Risks Related to the Coronavirus
- Mar 06, 2020
- Publications
Mitigating Cybersecurity Risks Related to the Coronavirus
To limit the spread of COVID-19, many companies are implementing contingency plans for employees to work remotely. These steps may, however, inadvertently increase the risks of a data breach or other cyberattack. We suggest practical…
Ring LLC Faces a Proposed Class Action Alleging Camera Doorbells Should Incorporate Enhanced Cybersecurity Features
- Feb 03, 2020
- Publications
Ring LLC Faces a Proposed Class Action Alleging Camera Doorbells Should Incorporate Enhanced Cybersecurity Features
On December 26, 2019, Amazon and Ring LLC were named as defendants in a putative class action filed in the U.S. District Court for the Central District of California by plaintiffs alleging claims of over $5 million.
Anti-Spoofing Enforcement: 2019 Year in Review
- Jan 28, 2020
- Publications
Anti-Spoofing Enforcement: 2019 Year in Review
2019 marked another unprecedented year in civil and criminal anti-spoofing enforcement.
Paul, Weiss Partners and Counsel Contribute Article on Cryptocurrency to DirectorCorps
- Dec 01, 2019
- Publications
Paul, Weiss Partners and Counsel Contribute Article on Cryptocurrency to DirectorCorps
Paul, Weiss partners Christopher Boehning, Roberto Gonzalez, Jeh Johnson, Claudine Meredith-Goujon, Lorin Reisner, Jeannie Rhee and Richard Tarlowe and counsel Steven Herzog published “Cryptocurrency Regulation Around the World: A…
Social Media Bot Company Devumi LLC Reaches $2.5 Million Settlement with FTC for Sale of Misleading Social Media “Influence Indicators”
- Oct 28, 2019
- Publications
Social Media Bot Company Devumi LLC Reaches $2.5 Million Settlement with FTC for Sale of Misleading Social Media “Influence Indicators”
On October 21, 2019, the Federal Trade Commission (“FTC”) settled its first-ever complaint against a company for selling fake indicators of social media influence such as phony likes, follows, views, and subscribers to users on…
Recent Cyber Attacks Target Asset Management Firms
- Oct 28, 2019
- Publications
Recent Cyber Attacks Target Asset Management Firms
A recent flurry of cyber attacks on asset managers should remind asset management firms and other financial institutions that they are attractive targets for cyber-exploitation and need to remain vigilant and institute appropriate…
CFTC Fines Phillip Capital for Failure to Prevent a Cyber Attack That Resulted in the Theft of Customer Funds
- Sep 23, 2019
- Publications
CFTC Fines Phillip Capital for Failure to Prevent a Cyber Attack That Resulted in the Theft of Customer Funds
On September 12, 2019, the Commodity Futures Trading Commission (“CFTC”) issued a consent order against Phillip Capital, Inc. (“Phillip”), a Chicago-based Futures Commission Merchant, requiring payment of a $500,000 penalty and $1…
Google and YouTube Pay Record $170 Million Fine for Allegedly Violating Children’s Privacy Law in Settlement with the FTC and the New York Attorney General
- Sep 09, 2019
- Publications
Google and YouTube Pay Record $170 Million Fine for Allegedly Violating Children’s Privacy Law in Settlement with the FTC and the New York Attorney General
On September 4, 2019, the Federal Trade Commission (the “FTC”) and the New York Attorney General’s Office (the “NYAG”) reached a record $170 million settlement with Google and YouTube for alleged violations of the Children’s Online…
New York Governor Signs Data Security Law
- Jul 31, 2019
- Publications
New York Governor Signs Data Security Law
On July 25, 2019, New York Governor Andrew M. Cuomo signed into law a new data security law, the Stop Hacks and Improve Electronic Data Security (“SHIELD”) Act.
New York DFS Creates New Cybersecurity Division
- May 29, 2019
- Publications
New York DFS Creates New Cybersecurity Division
On May 22, 2019, the New York State Department of Financial Services (“DFS”) announced the creation of a new Cybersecurity Division, which it described as the “first of its kind at a banking or insurance regulator.”
DOJ Updated Guidance for Evaluating Corporate Compliance Programs Focuses on Effectiveness
- May 06, 2019
- Publications
DOJ Updated Guidance for Evaluating Corporate Compliance Programs Focuses on Effectiveness
On April 30, 2019, the Criminal Division of the U.S. Department of Justice released updated guidance on how prosecutors evaluate the effectiveness of corporate compliance programs.
Anti-Spoofing Enforcement: 2018 Year in Review
- Jan 07, 2019
- Publications
Anti-Spoofing Enforcement: 2018 Year in Review
The past year brought a number of significant developments in anti-spoofing enforcement under the Commodity Exchange Act (“CEA”), beginning with the January 29, 2018 coordinated statements of the Commodity Futures Trading Commission…
DOJ Announces New Standards for Corporate Cooperation
- Dec 05, 2018
- Publications
DOJ Announces New Standards for Corporate Cooperation
The Department of Justice announced last week significant changes to its policies for granting corporations credit for cooperating with criminal investigations.
DOJ Announces New Guidance for Imposing Compliance Monitors in Criminal Division Matters
- Oct 17, 2018
- Publications
DOJ Announces New Guidance for Imposing Compliance Monitors in Criminal Division Matters
On October 12, 2018, Brian A. Benczkowski, the Assistant Attorney General for the Criminal Division, announced new guidance (the “Benczkowski Memorandum”) setting forth a “pragmatic approach to monitorships,” highlighting the factors…
The New York Court of Appeals Rules That Martin Act Claims Are Subject to a Three-Year Statute of Limitations
- Jun 14, 2018
- Publications
The New York Court of Appeals Rules That Martin Act Claims Are Subject to a Three-Year Statute of Limitations
On June 12, 2018, in People v. Credit Suisse Securities (USA) LLC, et al., the New York Court of Appeals held that claims brought under the Martin Act—New York’s uniquely broad Blue Sky Law, a powerful tool that permits the Attorney…
Richard Tarlowe to Participate in PLI Seminar on Internal Investigations
- Jun 22, 2018
- Events
Richard Tarlowe to Participate in PLI Seminar on Internal Investigations
Litigation partner Richard Tarlowe will speak on a panel at the Practising Law Institute program, “Internal Investigations 2018.”
Supreme Court Rules That Costs of Internal Investigation Are Not Recoverable As Restitution under the Mandatory Victims Restitution Act of 1996
- May 30, 2018
- Publications
Supreme Court Rules That Costs of Internal Investigation Are Not Recoverable As Restitution under the Mandatory Victims Restitution Act of 1996
On May 29, 2018, in Lagos v. United States, the Supreme Court unanimously held that the Mandatory Victims Restitution Act of 1996 (the “MVRA”)[1] does not require a criminal defendant to pay the costs and attorneys’ fees associated…
DOJ Issues New Policy on Coordination of Corporate Penalties to Address “Piling On”
- May 10, 2018
- Publications
DOJ Issues New Policy on Coordination of Corporate Penalties to Address “Piling On”
Yesterday, Rod Rosenstein, Deputy Attorney General of the U.S. Department of Justice, announced a new policy, in the form of an addition to the United States Attorneys’ Manual (“USAM”), concerning the coordination of corporate…
United States v. Litvak: Second Circuit Rejects Challenge to the Materiality of Misstatements but Overturns Conviction a Second Time Due to Agency-Relationship Testimony
- May 07, 2018
- Publications
United States v. Litvak: Second Circuit Rejects Challenge to the Materiality of Misstatements but Overturns Conviction a Second Time Due to Agency-Relationship Testimony
On May 3, 2018, for the second time, the Court of Appeals for the Second Circuit overturned the conviction of former Jefferies trader Jesse Litvak for alleged misstatements to an RMBS transaction counterparty.
Yahoo! Agrees to $35 Million SEC Penalty for Failure to Disclose Cyber Incident
- May 03, 2018
- Publications
Yahoo! Agrees to $35 Million SEC Penalty for Failure to Disclose Cyber Incident
On April 24, 2018, the Securities and Exchange Commission announced that Altaba, the company formerly known as Yahoo! Inc., agreed to pay a $35 million penalty as part of a cease-and-desist order to settle charges that it misled…
Implications of the New EU Data Protection Regime and Its Expanded Application for Non-EU Entities
- Apr 26, 2018
- Publications
Implications of the New EU Data Protection Regime and Its Expanded Application for Non-EU Entities
The EU General Data Protection Regulation (the “GDPR”), approved and adopted by the European Union in April 2016, takes effect in all member states of the European Union on May 25, 2018.
Supreme Court Dismisses Microsoft Appeal as Moot After Passage of the CLOUD Act
- Apr 23, 2018
- Publications
Supreme Court Dismisses Microsoft Appeal as Moot After Passage of the CLOUD Act
As reported in our earlier client memorandum, in February 2018, the U.S. Supreme Court heard argument in United States Microsoft Corp., a case concerning the government’s ability to compel U.S. service providers to disclose email…
Marvel Entertainment Chairman Prevails in First Department Appeal in Defamation Case
- Apr 09, 2018
- Client News
Marvel Entertainment Chairman Prevails in First Department Appeal in Defamation Case
Paul, Weiss prevailed in an appeal seeking a protective order on behalf of Isaac “Ike” Perlmutter, chairman of Marvel Entertainment.
U.S. Supreme Court Hears Oral Argument on Extraterritorial Reach of Email Search Warrants in Microsoft Case
- Feb 28, 2018
- Publications
U.S. Supreme Court Hears Oral Argument on Extraterritorial Reach of Email Search Warrants in Microsoft Case
In a case that could have a major impact on how and where corporations store their customers’ electronic information, the U.S. Supreme Court heard oral arguments yesterday in United States v. Microsoft Corp. on the extraterritorial…
Leaders of SEC Enforcement Division Discuss Priorities and Recent Developments
- Feb 28, 2018
- Publications
Leaders of SEC Enforcement Division Discuss Priorities and Recent Developments
Senior representatives of the SEC’s Enforcement Division recently discussed enforcement priorities, developments and other issues of current interest at the Practising Law Institute’s annual “SEC Speaks” event. Although the…
SEC Issues Updated Guidance on Cybersecurity Disclosure
- Feb 27, 2018
- Publications
SEC Issues Updated Guidance on Cybersecurity Disclosure
The SEC recently provided updated guidance on cybersecurity-related disclosure obligations. We discuss the SEC’s new interpretive guidance, which seeks to assist companies in preparing disclosure concerning cybersecurity risks and…
Beyond Disgorgement: The Impact of Kokesh on the SEC’s Pursuit of Equitable Remedies
- Feb 23, 2018
- Publications
Beyond Disgorgement: The Impact of Kokesh on the SEC’s Pursuit of Equitable Remedies
Since the Supreme Court ruled last June in Kokesh v. SEC that disgorgement claims are subject to a five-year statute of limitations, both lower courts and the SEC have grappled with questions the Court left unresolved, including…
U.S. Supreme Court Narrows Scope of Whistleblower Anti-Retaliation Protections
- Feb 22, 2018
- Publications
U.S. Supreme Court Narrows Scope of Whistleblower Anti-Retaliation Protections
The Supreme Court held yesterday that individuals who have reported alleged misconduct internally, but not to the SEC, are not covered by the anti-retaliation provisions of the Dodd-Frank Act, resolving a circuit split on the…
Recent Decision Finds Waiver Based on “Oral Downloads” to the SEC
- Feb 14, 2018
- Publications
Recent Decision Finds Waiver Based on “Oral Downloads” to the SEC
A federal magistrate judge in the Southern District of Florida recently ruled that a law firm had waived work product protection over notes and memoranda of witness interviews when it provided “oral downloads” of those interviews to…
Recent Public Remarks by Co-Directors of SEC Enforcement Division Signal Potential Changing Enforcement Priorities
- Oct 31, 2017
- Publications
Recent Public Remarks by Co-Directors of SEC Enforcement Division Signal Potential Changing Enforcement Priorities
Recent remarks by top officials at the SEC’s Division of Enforcement suggest changes in the enforcement environment, including a de-emphasis on the “broken windows” strategy focusing on minor violations and on settlements requiring…
Divided Second Circuit Panel Overrules Prior Newman Insider Trading Decision
- Aug 25, 2017
- Publications
Divided Second Circuit Panel Overrules Prior Newman Insider Trading Decision
On Wednesday, in United States v. Martoma, the United States Court of Appeals for the Second Circuit overruled its own 2014 decision in United States v. Newman and altered the standard for determining whether the personal benefit…
Omega Advisors and Leon Cooperman Settle SEC Charges
- May 18, 2017
- Client News
Omega Advisors and Leon Cooperman Settle SEC Charges
After a six-year investigation, Paul, Weiss clients Omega Advisors, Inc. and Leon Cooperman agreed to settle claims filed by the Securities and Exchange Commission based on allegations of insider trading and late filings of statements …
Cybersecurity Enforcement Trends and Developments
- Apr 06, 2017
- Videos
Cybersecurity Enforcement Trends and Developments
Recently, a number of federal and state agencies have asserted their jurisdiction in the cybersecurity space through enforcement actions.
Air Methods to Be Acquired by American Securities
- Mar 14, 2017
- Client News
Air Methods to Be Acquired by American Securities
Paul, Weiss is representing Air Methods Corporation in its proposed acquisition by affiliates of American Securities LLC.
Brad Karp, Lorin Reisner, Richard Tarlowe and Edward Turan to Speak at SIFMA’s Compliance and Legal Society Annual Seminar
- Mar 19, 2017
- Events
Brad Karp, Lorin Reisner, Richard Tarlowe and Edward Turan to Speak at SIFMA’s Compliance and Legal Society Annual Seminar
Litigation partners Brad Karp, Lorin Reisner, Richard Tarlowe and counsel Edward Turan will speak at the 2017 SIFMA Compliance and Legal Society’s Annual Seminar—the securities industry’s premiere event.
Client Alert: The Regulatory and Enforcement Outlook for Financial Institutions in 2017
- Feb 22, 2017
- Publications
Client Alert: The Regulatory and Enforcement Outlook for Financial Institutions in 2017
Economic sanctions, anti-money laundering and cybersecurity remain at the forefront of U.S. regulatory priorities. In this memorandum, we survey major developments and trends in these areas in 2016 and early 2017 and provide an…
U.S. Supreme Court to Review Whether Statute of Limitations Applies to SEC Disgorgement Claims
- Jan 17, 2017
- Publications
U.S. Supreme Court to Review Whether Statute of Limitations Applies to SEC Disgorgement Claims
On January 13, 2017, the Supreme Court granted certiorari in Kokesh v. Securities and Exchange Commission (U.S. Jan. 13, 2017) (No. 16-529) to determine whether disgorgement claims are subject to the five-year statute of limitations…
Client Alert: Supreme Court Reaffirms Dirks, Confirms that a Gift of Information to a Trading Relative or Friend Satisfies Personal Benefit Requirement for Insider Trading
- Dec 07, 2016
- Publications
Client Alert: Supreme Court Reaffirms Dirks, Confirms that a Gift of Information to a Trading Relative or Friend Satisfies Personal Benefit Requirement for Insider Trading
In its first opinion on the scope of insider trading liability in nearly twenty years, the Supreme Court in Salman v. United States addressed whether insider trading liability can arise where a tipper makes a "gift" of…
Paul, Weiss Announces Election of Three New Partners
- Dec 02, 2016
- Firm News
Paul, Weiss Announces Election of Three New Partners
Paul, Weiss has announced that three new partners have been elected to the partnership, effective January 1, 2017: David M. Klein, Brian C. Lavin and Richard C. Tarlowe. All are resident in Paul, Weiss's New York office.
Client Alert: Federal Banking Agencies Issue Advanced Notice of Proposed Rulemaking on Enhanced Cybersecurity Standards
- Oct 21, 2016
- Publications
Client Alert: Federal Banking Agencies Issue Advanced Notice of Proposed Rulemaking on Enhanced Cybersecurity Standards
On October 19, the Federal Reserve Board ("Board"), the Federal Deposit Insurance Corporation ("FDIC"), and the Office of the Comptroller of the Currency ("OCC") jointly issued an advanced notice of proposed rulemaking ("ANPR")…
Client Alert: What to Look for in Tomorrow’s Supreme Court Argument in Key Insider Trading Case
- Oct 04, 2016
- Publications
Client Alert: What to Look for in Tomorrow’s Supreme Court Argument in Key Insider Trading Case
For the first time in nearly twenty years, the United States Supreme Court will hear oral argument tomorrow in a case directly addressing the scope of insider trading liability.
Client Alert: New York DFS Proposes New Rules on Cybersecurity
- Sep 15, 2016
- Publications
Client Alert: New York DFS Proposes New Rules on Cybersecurity
On Tuesday, the New York Department of Financial Services ("DFS") proposed new rules that would require covered financial institutions to establish and maintain cybersecurity programs designed to protect consumers and the…
Richard Tarlowe Presents Cyber Theft Case Study at ABA Business Law Section’s Annual Meeting
- Sep 08, 2016
- Events
Richard Tarlowe Presents Cyber Theft Case Study at ABA Business Law Section’s Annual Meeting
Litigation counsel Richard Tarlowe was a presenter for a program entitled "Bangladesh Central Bank: A Case Study in Cyber Theft" at the American Bar Association Business Law Section's annual meeting.
Client Alert: FinCEN Issues Sweeping New Requirements on Collection of Beneficial Ownership Information and Customer Due Diligence
- May 10, 2016
- Publications
Client Alert: FinCEN Issues Sweeping New Requirements on Collection of Beneficial Ownership Information and Customer Due Diligence
On May 6, 2016, the U.S. Treasury Department's Financial Crimes Enforcement Network ("FinCEN") released a final rule codifying new and existing customer due diligence ("CDD") requirements under the Bank Secrecy Act ("BSA") for covered …
Client Alert: The CFPB Enters the Cybersecurity Arena with Its First Enforcement Action
- Mar 04, 2016
- Publications
Client Alert: The CFPB Enters the Cybersecurity Arena with Its First Enforcement Action
On March 2, the Consumer Financial Protection Bureau entered an enforcement order against online payment platform Dwolla, Inc. for deceiving consumers about its data security practices and the safety of its online payment system.
…Client Alert: New Federal Guidance on the Cybersecurity Information Sharing Act of 2015: What General Counsel Need to Know
- Feb 23, 2016
- Publications
Client Alert: New Federal Guidance on the Cybersecurity Information Sharing Act of 2015: What General Counsel Need to Know
The Cybersecurity Information Sharing Act of 2015 ("CISA") was signed into law on December 18, 2015. The law authorizes companies to monitor and implement defensive measures on their own information systems to counter cyber…
FinCEN Imposes Anti-Money Laundering Reporting Requirements
- Feb 02, 2016
- Publications
FinCEN Imposes Anti-Money Laundering Reporting Requirements
The U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN) issued Geographic Targeting Orders ("GTO") imposing temporary reporting requirements on title insurers with respect to "all-cash" purchases of high-end…
Richard Tarlowe Participates in NYLJ In-House Counsel CLE Seminar
- Nov 06, 2015
- Events
Richard Tarlowe Participates in NYLJ In-House Counsel CLE Seminar
Litigation counsel Richard Tarlowe participated in a panel discussion, "Ethics: eDiscovery, Social Media, and the Internet of Things," as part of the New York Law Journal's In-House Counsel CLE program.
Cybersecurity Update: Heightened Concerns, Legal and Regulatory Framework, Enforcement Priorities, and Key Steps to Limit Legal and Business Risks
- Sep 30, 2015
- Publications
Cybersecurity Update: Heightened Concerns, Legal and Regulatory Framework, Enforcement Priorities, and Key Steps to Limit Legal and Business Risks
Recently reported cyber incidents have impacted millions of people and exposed the increased and continuing risks for businesses and government agencies.
Client Alert: OCIE Issues Additional Information on Cybersecurity Examination Initiative
- Sep 17, 2015
- Publications
Client Alert: OCIE Issues Additional Information on Cybersecurity Examination Initiative
The SEC's Office of Compliance Inspections and Examinations ("OCIE") recently published additional information on the areas of focus for OCIE's second round of cybersecurity examinations of registered investment advisers…
Client Alert: New DoJ Memo by DAG Yates Intended to Increase Prosecutions of White Collar Executives and Other Employees
- Sep 11, 2015
- Publications
Client Alert: New DoJ Memo by DAG Yates Intended to Increase Prosecutions of White Collar Executives and Other Employees
In a speech yesterday at NYU Law School, Deputy Attorney General Sally Q. Yates announced new Department of Justice policies intended to strengthen the DoJ's efforts to hold corporate executives accountable for unlawful conduct.
Richard Tarlowe Quoted in Cybersecurity Law Report
- May 20, 2015
- Publications
Richard Tarlowe Quoted in Cybersecurity Law Report
Litigation counsel Richard Tarlowe was quoted in a Cybersecurity Law Report article about the Department of Justice's recently issued best practices for cyber incident reporting.
Leading Federal Prosecutor Joins Paul, Weiss
- Feb 04, 2015
- Firm News
Leading Federal Prosecutor Joins Paul, Weiss
Paul, Weiss, Rifkind, Wharton & Garrison LLP announced today that Richard C. Tarlowe, Chief of the Complex Frauds and Cybercrime Unit of the U.S. Attorney's Office for the Southern District of New York and a former member of its…