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Chris Murphy

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Chris Murphy is an associate in the New York office of Crowell & Moring, and a member of the firm’s Antitrust and Competition and White Collar and Regulatory Enforcement practices. His practice is focused on counseling and representing corporate and individual clients in regulatory enforcement actions, government investigations, white collar criminal defense matters, and internal investigations. Chris counsels large companies in risk-assessment and regulatory compliance as well as individual clients on complex civil litigation issues. Chris represents corporations and executives in criminal and related regulatory and complex civil matters, including internal investigations and parallel proceedings by the U.S. Department of Justice, Securities and Exchange Commission, and State Attorneys Generals.

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On Monday, September 23, 2024, the Department of Justice (DOJ), released an update to its Evaluation of Corporate Compliance Programs (ECCP) guidance.  The ECCP guidance was last revised in March 2023, which brought a number of significant changes, including a focus on compensation and incentive structures (e.g., clawbacks), and third party messaging applications.  This 2024 update, while not as significant in scope as its predecessor, nonetheless highlights the DOJ’s focus on new and emerging technologies, such as artificial intelligence (AI), as part of its evolving assessment of what makes a corporate compliance program truly effective, and how prosecutors should evaluate risk assessments and other management tools at the time of a corporate resolution.Continue Reading Putting the “AI” in Compliance—DOJ Updates its Corporate Compliance Program Guidance to Address Emerging AI Risks and Leveraging Data 

On June 26, 2024, a 6-3 majority of the U.S. Supreme Court narrowed the scope of federal bribery law by ruling that 18 U.S.C. § 666 does not cover gratuities provided to officials for past acts. The Court held that Section 666, which outlaws bribery of state and local officials when federal funds are involved, does not extend to “gratuities” that follow an official act, in large part because regulation of such gifts is a matter of state and local law. Continue Reading Supreme Court Rules Gratuity Insufficient For Conviction Under Federal Bribery Law