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Can A Single FTC Commissioner Constitute A Quorum?

Partner John Villafranco co-authored the Law360 article Can A Single FTC Commissioner Constitute A Quorum?” The article discusses if the FTC can take formal action by a 1-0 vote and raises the question of when a commission ceases being a commission.


Kelley Drye’s White Collar, Investigations and Compliance practice group, comprised of former federal prosecutors and a Certified Anti-Money Laundering Specialist®, understands the perspective of law enforcement and regulators and uses that understanding to advise clients on civil and criminal fraud matters, anti-money laundering (AML) inquiries, and implementing corporate compliance and fraud prevention programs. The group also advises clients on emerging issues, such as state-legal marijuana-related businesses and cryptocurrency and blockchain technologies. Most recently the group advised on the federal and state laws implicated in publishing advertisements for a state-legal marijuana business; appeared on MSNBC to discuss the intricacies of money laundering and the Paul Manafort investigation; litigated RICO claims; and provided AML and privacy compliance advice to consumer-facing businesses launching new products and services.

Kelley Drye keeps clients informed on White Collar, Investigations and Compliance issues through speaking and writing on timely issues, as well as conducting client-focused CLEs.

Highlights of the Group’s upcoming and recent activities include:

The Regulatory Environment Through a Commercial Lens
At the Institutional Capital Conference on May 21, 2018 in Las Vegas. the panel The Regulatory Environment Through a Commercial Lens” will address investors seeking alternative asset classes and portfolio diversification opportunities and explain the evolving regulatory environment at the local, state and federal levels. For more information and to register click here.

Roundtable Discussion: DOJ and DoD Perspective on Government Contracts and Investigations
BDO and Kelley Drye are hosting a roundtable discussion about DOJ and DoD enforcement priorities, investigations, and case studies in Washington D.C. on June 12th. The discussion is with Cristine Phillips, Deputy Chief of Civil Frauds Unit, U.S. Attorney’s Office, Southern District of New York and Mark Pohl, Special Agent for the U.S. Department of Defense, Office of the Inspector General, Defense Criminal Investigative Service (DCIS). To join us at the Ritz Carlton Pentagon City, please click here to RSVP.

Ask the Experts: Legal and Regulation Updates
Partner Matt Luzadder and Senior Associate Donnelly McDowell served on the Ask the Experts: Legal and Regulation Updates” April 10, 2018 panel at Flourish: The Growth of Branded Currency Conference. The session discussed latest updates and recent developments impacting gift cards, branded currency, and loyalty programs. The developments discussed included those in the area of privacy, money transmission regulation and escheatment law.


On May 3, 2018, Kelley Drye hosted the 2018 edition of its Advertising and Privacy Law Summit. The event provided updates and insight into key advertising and privacy issues as well as practical solutions on state attorney general enforcement actions and related investigations, consumer protection litigation, Ad Tech privacy issues, NAD challenges, influencer and celebrity marketing, Proposition 65, GDPR, and a look at what companies can do in the #MeToo world to be good corporate citizens.

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