Temidayo Aganga-Williams Speaks on the Future of Fraud and Bribery Prosecution at the ABA White Collar Crime Conference 2024

3/11/2024

Temidayo Aganga-Williams Speaks on the Future of Fraud and Bribery Prosecution at the ABA White Collar Crime Conference 2024

Partner Temidayo Aganga-Williams spoke at the 2024 ABA White Collar Crime Conference, on a panel titled “Ciminelli, Percoco, Varsity Blues and the Future of Fraud and Bribery Prosecutions.”  The panel covered the Supreme Court’s decisions in two important mail/wire fraud cases last term: Ciminelli v. United States and Percoco v. United States, as well as the prominent “Varsity Blues” prosecution in the First Circuit (United States v. Abdelaziz).

In Ciminelli, the Court rejected the right-to-control fraud theory and held that federal fraud statutes touch only schemes aimed at traditional property interests, like money, and not “mere information.”  In Percoco, the Court further narrowed the scope of the honest services fraud statute.  In the Varsity Blues case, the First Circuit overturned fraud and bribery convictions in the context of private universities. Unpacking the background and impact of these decisions, Temidayo and his fellow panelists discussed how the Supreme Court’s approach to these criminal statutes will impact future federal fraud and corruption prosecutions.

Temidayo was joined by Lorin Reisner of Paul, Weiss, Rifkind, Wharton & Garrison LLP, David Saratt of Debevoise & Plimpton LLP, Tom Hanusik of Crowell & Moring LLP, David Angeli of Angeli Law Group LLC, Brent Wible of the Office of the Assistant Attorney General at the U.S. Department of Justice, Criminal Division, and Jonathan Sack of Morvillo Abramowitz Grand Iason & Anello PC, who moderated the panel.

The annual White Collar Crime Conference is hosted by the American Bar Association.  It is the leading American conference on white collar practice, including investigations, trials, and enforcement matters.