Investigations and Regulatory Enforcement

Cravath represented Circle Internet Financial, LLC on SEC regulatory matters concerning the non‑applicability of securities laws to payment stablecoins, concurrent with Circle Internet Group Inc.’s initial public offering.

On January 22, 2025, Eros Media World plc, a global media and entertainment company, announced that its internal review of certain accounting practices and internal controls has been concluded, with the Audit Committee determining that no revenues of the Company recognized during the fiscal year ended March 31, 2020, were inappropriately recognized, and finding no impairment in the intangible assets and goodwill reflected on the Company’s Form 6‑K dated March 31, 2021. In addition, the Audit Committee found no material weaknesses in internal controls over financial reporting.

On July 1, 2024, Silvergate announced it has agreed to settlements with the Board of Governors of the Federal Reserve System (“Federal Reserve”), the California Department of Financial Protection and Innovation (“DFPI”) and the Securities and Exchange Commission (“SEC”). In a statement, Silvergate noted its decision to liquidate voluntarily and without government assistance in March 2023, and that, as of November 2023, all deposits had been repaid to banking customers, soon after which Silvergate ceased banking operations. The announced settlements, which facilitate the surrender of Silvergate’s bank charter, are part of the Bank’s continued orderly wind down and conclude investigations by the Federal Reserve, DFPI, and SEC. Cravath represented Silvergate in connection with the investigations, resulting settlements, and voluntary liquidation.

Cravath represented the underwriters in connection with the $1.5 billion offering of depositary shares representing preferred stock of State Street Corporation, a provider of a broad range of financial products and services to institutional investors worldwide. The transaction closed on January 31, 2024.

AerCap Holdings N.V, the world’s largest commercial aircraft leasing company, which Cravath is representing in connection with U.S. sanctions and export controls matters, has secured over $1.2 billion in related insurance recoveries involving Russian airlines’ refusal to return over 100 aircraft leased from AerCap following Russia’s invasion of Ukraine in February 2022. In September 2023, in the first announced insurance settlement of its kind, Cravath represented AerCap in obtaining authorizations from the U.S. Office of Foreign Assets Control (“OFAC”) and the U.S. Department of Commerce’s U.S. Bureau of Industry and Security (“BIS”) for an agreement to enable payment of approximately $645 million to AerCap to resolve claims against certain Russian insurers and airlines as to a substantial number of AerCap aircraft. Cravath also represented AerCap before BIS and OFAC in connection with AerCap’s subsequent, $572 million insurance settlements with Russian insurers and airlines announced in December 2023.

On June 13, 2025, Lawdragon announced the inclusion of 18 Cravath partners in its inaugural list of “500 Global Leaders in Crisis Management.” The list, assembled based on research and vetting by peers, recognizes “the world’s leading minds in the art of calming, managing, defusing and ‘handling’ matters that threaten an institution, whether a global corporation, powerful individual, nonprofit or other entity.” 

On June 10, 2025, Cravath partner Nicole M. Argentieri participated in the American Conference Institute’s 23rd New York Forum on Global Anti‑Corruption, Ethics & Compliance, which was held from June 10‑11 in New York. The forum convened compliance leaders and experts from law firms, government and the private sector to discuss new insights, best practices and practical strategies on compliance risks and regulatory enforcement. Nicole spoke on a panel entitled “Current and Former DOJ and SEC Officials Unpack New White‑Collar Enforcement Priorities and Policies and What They Mean for Compliance and Internal Investigations Professionals,” during which panelists discussed the evolving landscape of enforcement and new priorities at the DOJ and SEC, as well as practical takeaways for updating risk management, internal investigations and compliance strategies.

On May 2, 2025, Cravath partners David J. Kappos, John D. Buretta, Noah Joshua Phillips, Sasha Rosenthal‑Larrea, Evan Norris, Michael L. Arnold and Kimberley S. Drexler were named to Lawdragon’s list of “500 Leading Global Cyber Lawyers” in recognition of their work advising clients on incident response and preparation, corporate governance and disclosure matters, investigations and regulatory enforcement, and transactional and competition matters related to data privacy and cybersecurity. The list recognizes “world leaders in privacy, data, security, incident response, and the deals and lawsuits that revolve around all things Cyber.”

On April 15, 2025, Cravath prepared a memo for its clients entitled “DOJ Announces New Digital Asset Enforcement Priorities.” The memo examines the Office of the Deputy Attorney General’s recently issued memorandum with the subject “Ending Regulation By Prosecution,” which sets out new enforcement priorities for digital asset‑related investigations and prosecutions by the U.S. Department of Justice.

On March 18, 2025, Cravath partner Evan Norris participated in the International Chamber of Commerce Mexico and the Anticorruption Commission’s IX Anticorruption Postgraduate Course, hosted in collaboration with Universidad Panamericana. The course brought together high‑level government officials, legal scholars and practitioners for sessions on combatting national and global corruption. Evan’s session focused on developments in U.S. criminal enforcement in sports.