How INTERPOL's CCF Can Reduce Its Backlog and Become More Efficient by The Law Office of Michelle A. Estlund, P.A. on 5/23/2012 In the last post, we addressed the fact that the Commission for the Control of INTERPOL's Files (CCF) is still required under its operating rules to meet only three times per year. This requirement has remained the same in...more
EPIC Urges the Drug Enforcement Administration to Uphold Privacy Act Protections by Electronic Privacy Information Center on 5/22/2012 In response to a notice of proposed rulemaking, EPIC has submitted comments to the Drug Enforcement Administration of the Department of Justice, urging the agency to uphold Privacy Act protections, and to not claim broad...more
FSA Fines Martin Currie £3.5 million for Conflict of Interests Failures by Katten Muchin Rosenman LLP on 5/22/2012 On May 10, the UK Financial Services Authority (FSA) announced that it fined Martin Currie Investment Management Limited and Martin Currie Inc (together, Martin Currie) £3.5 million (approximately $5.5 million) for conflict...more
Sanctions Enforcement — An Increasing Risk by Michael Volkov on 5/22/2012 Everyone writes about the FCPA and the UK Bribery Act. Some are more willing to tackle export compliance. Given the Obama Administration’s reliance on sanctions as a foreign policy tool, companies need to address the...more
FSA Fines Habib Bank and its Money Laundering Reporting Officer for AML Control Failings by Katten Muchin Rosenman LLP on 5/22/2012 On May 15, the UK Financial Services Authority (FSA) announced that it had fined Habib Bank AG Zurich (Habib Bank) £525,000 (approximately $830,000) and Syed Itrat Hussain (Hussain) its former Money Laundering Reporting...more
HIPAA Criminal Penalties – Defendant May Be Found Guilty without “Knowledge” That Acts Are Illegal by Mintz Levin - Health Law on 5/21/2012 Individuals who access protected health information without authorization may be found guilty of a misdemeanor even if they lack knowledge that their actions are illegal. ...more
Nightmare Scenarios for an Internal Investigation by Michael Volkov on 5/21/2012 Everyone has tips on how to conduct internal investigations. The how-to articles present advice on how to conduct an internal investigation. Unfortunately, the reality is far more complex and risky. Behind many of the...more
Ministry of Justice Seeks Consultation on the Introduction of Deferred Prosecution Agreements in the UK by Bryan Cave on 5/21/2012 The Ministry of Justice yesterday initiated a consultation process following its proposal to introduce Deferred Prosecution Agreements (DPAs) in the United Kingdom as an enforcement tool to combat economic crimes by...more
INTERPOL's Grievance Process: Time for a Full-Time Commission? by The Law Office of Michelle A. Estlund, P.A. on 5/21/2012 The process for seeking relief from an improperly issued Red Notice currently requires that the request be reviewed by the Commission for the Control of INTERPOL's Files. The Commission is made up of five individuals from...more
Sexual Harassment Policy by WASIM AKHTAR on 5/18/2012 Government of Pakistan announced Sexual harassment policy 2012...more
Championing the UK Bribery Act: The 2012 Olympic Games and Corporate Hospitality by McDermott Will & Emery on 5/17/2012 Since it came into force on 1 July 2011, the impact of the UK Bribery Act 2010 (the Act) on the giving of corporate hospitality, gifts and other expenses has raised concerns among those who fall under the Act’s jurisdiction. ...more
A Man Overboard Will Not Sink the Ship: How Robust FCPA Compliance Can Keep a Company Out of Hot Water Even When An Executive is... by Sheppard Mullin Richter & Hampton LLP on 5/17/2012 The story of one man prosecuted by the SEC and the DOJ for an FCPA violation may run a little below the radar these days, when allegations of bribery by manufacturing, retail, and entertainment companies plaster the...more
Switzerland Responds to Wegelin Indictment and DOJ’s Relentless Pursuit of Offshore Bank Account Information by Sheppard Mullin Richter & Hampton LLP on 5/16/2012 On February 2, 2012, Wegelin & Co., Switzerland’s oldest private bank, became the first overseas bank to be indicted by the United States for aiding tax fraud—but it may not be the last. The company is one of at least 11...more
The Implications of the Laura Stevens Criminal Prosecution by Michael Volkov on 5/16/2012 I have spoken to several in-house counsel meetings about the Laura Stevens criminal case. It is amazing to me how many have not heard about the case or appreciates the implications for in-house counsel and especially global...more
Non-compliance with U.S. Anticorruption Law: Are you losing millions in company value? by Duane Morris LLP on 5/16/2012 Originally published in Asian-Mena Counsel- Volume 10 Issue 1, 2012 On a recent trip to Asia, I was asked by an Indian CEO, “Why does the application of U.S. law matter to an Asian company?” In my experience, many...more