Erin Sullivan

Erin Sullivan

Bradley Arant Boult Cummings LLP

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Dealing with high-risk clients and final advice for maintaining an effective AML compliance program

Dealing with high-risk clients in an era of enhanced AML enforcement - To identify and trace criminal activity, federal law enforcement relies on the mandatory filing of suspicious activity reports (SARs) by financial...more

4/23/2015 - BSA/AML Chief Compliance Officers Compliance Enforcement Financial Institutions FinCEN Money Services Business SAR

Avoiding personal liability amidst heightened AML enforcement

In February 2014, the Financial Industry Regulation Authority (FINRA), the self-regulatory body for the U.S. securities industry, suspended a former global anti-money laundering compliance officer at Brown Brothers Harriman &...more

3/5/2015 - Anti-Money Laundering Bank Secrecy Act Chief Compliance Officers Corporate Culture Enforcement Actions FINRA Personal Liability

Heightened Enforcement Efforts Focus on Financial Institutions’ ‘Culture of Compliance’

The first of a three-part series on the new landscape of anti-money laundering enforcement - During hearings conducted in 2012 by the U.S. Senate’s Permanent Subcommittee on Investigations, Senator Tom Coburn commented...more

2/2/2015 - Anti-Money Laundering Banking Sector BSA/AML Chief Compliance Officers Compliance Corporate Culture Enforcement Enforcement Actions Ethics OCC

Alstom Guilty Plea Sends Strong Message that DOJ Has Harsh View of Inadequate Internal Controls and Failure to Fully Cooperate

On December 22, 2014, French power and transportation company Alstom S.A. (“Alstom”) pleaded guilty to violating the Foreign Corrupt Practices Act (“FCPA”) and agreed to pay $772.29 million, the largest criminal fine ever...more

1/20/2015 - Alstom Books & Records Bribery C-Suite Executives China Deferred Prosecution Agreements DOJ Energy Sector Enforcement Actions FCPA Foreign Official Foreign Subsidiaries Indictments Internal Controls Popular Subsidiaries

Department of Justice Cites Poor Compliance Program and Lack of Cooperation in Extracting Significant FCPA Penalties in Marubeni...

The importance of a company’s response to a Department of Justice (“DOJ”) investigation into possible violations of the Foreign Corrupt Practices Act (“FCPA”) was highlighted last week when Marubeni Corporation (“Marubeni”)...more

3/25/2014 - Compliance DOJ Enforcement Actions FCPA Penalties

The Foreign Corrupt Practices Act—A Look Back at 2012 and 2013

Over the last two years, enforcement of the Foreign Corrupt Practices Act (“FCPA”) has remained a priority of the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”). That emphasis is likely to...more

1/14/2014 - Anti-Corruption Compliance Corruption DOJ Enforcement Enforcement Actions FCPA Fraud SEC

The First Circuit Joins the D.C. Circuit in Hampering Relators’ Ability to Bring Duplicative Actions Under the False Claims Act’s...

The First Circuit has become the fourth federal court of appeals to address whether a first-filed yet insufficient complaint still qualifies as a pending action under the first-to-file rule of the False Claims Act....more

6/4/2013 - False Claims Act First-to-File Fraud Notice Requirements Pleading Standards

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