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Update: Crackdown on Casino AML Deficiencies Continues as Caesars Entertainment Corp. becomes subject of FinCEN and DOJ...

On October 21, 2013, Caesars Entertainment Corp. (“Caesars”) announced in its filing with the Securities and Exchange Commission that its subsidiary Desert Palace, Inc. (owner of Caesars Palace) was under investigation for...more

White Collar Watch - September 2013

Contents - FDIC filing more suits against officers and directors of failed financial institutions - Third Circuit upholds 12-year prison sentence for former BigLaw associate - Health care executives...more

The Penalties Applicable to Legal Entities Convicted for Corruption under French Law - Are the Administrative Consequences the...

Under French law, an act of corruption is exclusively subject to criminal liability; there is no administrative liability. Specific rules of administrative laws, however, which provide that a company convicted by a final...more

FBI's Mortgage Fraud Report as Prepared by the Financial Crimes Intelligence Unit

The objective of this study is to provide FBI program managers and the general public with relevant data to better understand the threat posed by mortgage fraud. The report was requested by the Financial Crimes Section,...more

Federal Government, Illinois AG Team Up To Bring First TARP Criminal Charges

On August 6, the Special Inspector General for the Troubled Asset Relief Program (TARP), the FDIC Office of Inspector General, and Illinois Attorney General Lisa Madigan announced criminal charges against former members of...more

DEPARTMENT OF JUSTICE PRESS RELEASE Re: Government Restated their Statistics because it "Got Caught Red-Handed" by Bloomberg News

LIES: Eric Holder Owes the American People an Apology When Holder first trotted out these figures last October, he bragged during a press conference about the results of the government’s “Distressed Homeowner Initiative,”...more

Brazilian FCPA-Equivalent Signed Into Law

On August 1, 2013, amid mounting pressure from disgruntled sectors of the Brazilian society and unrelenting street demonstrations across the country's largest cities – not to mention historic low approval ratings – President...more

Private Prosecutions - An Often Overlooked Method of Corporate Enforcement in England and Wales

In Ireland, a hotelier has initiated a private prosecution against a current and a former employee of an Irish bank. The hotelier was a director and shareholder of two companies which apparently owed a significant amount to...more

SIGTARP's Pursuit of TARP-Related Misconduct – No End in Sight

On July 24, 2013, the Office of the Special Inspector General for the Troubled Asset Relief Program (“SIGTARP”) filed its latest Quarterly Report to Congress (the “July Report”). The July Report summarizes SIGTARP’s recent...more

Joint Ventures: Sanctions and Corruption Risks

Expansion into both new and emerging markets is a continuing trend for companies across many industry sectors. In a number of jurisdictions, local law restricts foreign companies from establishing wholly owned subsidiaries -...more

Selling Stock Through the President’s Desk Drawer

Look inside the desk drawer of many, if not most, community bank presidents and you will find a list of the names of individuals who want to buy or sell the bank’s stock. ...more

Canada Continues Its Aggressive Push In Anti-Corruption Enforcement

Several years ago, Canada was regularly cited for its lack of commitment to anti-corruption enforcement. Canada got the message and it ramped up its anti-corruption program....more

Serious Fraud Office Issues Draft Code of Practice on Deferred Prosecution Agreements

On 27th June 2013, the UK announced more details of new rules that would introduce Deferred Prosecution Agreements (DPAs) into the UK for corporate offences. DPAs have been the weapon of choice for US regulators when...more

UK Law: Deferred Prosecution Agreements Appear a Step Closer

Deferred prosecution agreements (DPAs), whereby a prosecution for corporate crime is suspended in return for a promise of good behaviour, a possible fine and other conditions, appear likely to be introduced next year in the...more

SFO and DPAs: A Good Idea Begins to Spread

Last Thursday, the U.K. Serious Fraud Office released a draft Deferred Prosecution Agreement Code of Practices (Code) for comment. The draft Code represents a significant milestone for ethics and compliance in general, and...more

FORMER EXECUTIVE LORRAINE BROWN AT FLORIDA-BASED LENDER PROCESSING SERVICES INC. SENTENCED TO FIVE YEARS IN PRISON FOR ROLE IN...

Department of Justice Office of Public Affairs FOR IMMEDIATE RELEASE Tuesday, June 25, 2013 FORMER EXECUTIVE AT FLORIDA-BASED LENDER PROCESSING SERVICES INC. SENTENCED TO FIVE YEARS IN PRISON FOR ROLE IN...more

Keeping Internal Investigations Independent and Conflict-Free

Internal investigations can arise in a number of different ways and can concern a number of different subjects. Allegations of financial misconduct, employment-related missteps, and breaches of fiduciary duty, among others,...more

What Are The Essential Elements Of A Corporate Compliance Program?

Can you synthesize and reconcile the world’s leading laws, regulations and commentaries on the best practices an anti-bribery and anti-corruption compliance program. ...more

New Justice Department's FIRREA Cases Against Banks: Holding The Victim Responsible

The government’s ever-evolving response to the United States financial crisis has come full circle, as civil Justice Department Attorneys seek to rely on legislation enacted to protect financial institutions from fraud to sue...more

DOJ and SEC Scrutinize Potential Misuse of Rule 10b5-1 Trading Plans by Corporate Directors Affiliated with Investment Advisers

Over the past four years, the U.S. Department of Justice (“DOJ”) and U.S. Securities and Exchange Commission (“SEC”) have focused on insider trading involving private funds as one of their key targets in the fight against...more

Corporate Aspects of the UK Financial Services Act 2012

Long-heralded reform of the UK financial services regulation architecture impacts the listed company regime. On 1 April, a new financial regulation architecture became operative in the UK through the Financial...more

AML Enforcement – A New Era Of Compliance

Last year was the year of Bank Secrecy, sanctions and anti-Money Laundering enforcement. The HSBC settlement sparked significant controversy over the claim by the Justice Department that HSBC and other banks are “too big to...more

Q: Do You Tell The Central Bank What To Do? A: ‘In Which Country’?

Last weekend in the Financial Times (FT) was a report by Tim Burgis of an interview he held over a lunch meeting with the Angolan Isabel dos Santos, who Forbes magazine recently declared “the continent’s first female...more

Is China Getting Serious or Redirecting Responsibility? New guidance on Chinese Anti-Bribery Enforcement

For years, a significant number of Foreign Corrupt Practices Act (FCPA) enforcement actions have focused on or involved the People’s Republic of China (PRC), Chinese subsidiaries, or Chinese officials. It is hard to avoid...more

DOJ Announces Criminal Charges And Penalties For LIBOR Manipulation, Regulators Announce Parallel Civil Enforcement Actions

On February 6, U.S. and U.K. authorities announced that a Japanese financial institution and its British bank parent company agreed to pay roughly $612 million to resolve criminal and civil investigations into the firms’ role...more

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