How Ethical Behaviors Can "All Go So Wrong."
Front Line Interview Episode 1. Alison Taylor: Organizations, Compliance & Corruption
An FCPA Journey to the Darkside & Steps to Protect Your Organization
From Behind the Bribe: The Sharp End of Compliance
Legal Minute - SEC Enforcement Actions: Federal Court vs. In-House Proceedings
FCPA Compliance and Ethics Report-Episode 176-Tim Treanor on the PetroTiger Declination
FCPA Compliance and Ethics Report-Episode 168-Dan Cogdell on criminal procedure issues in defending an individual prosecuted criminally under the FCPA
Bribery & Corruption in the Military. A Front-Line View (Part II)
BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
Bribery & Corruption in the Military. A Front-Line View (Part I)
Richard Bistrong Weighs in on the FIFA Scandal and Takedowns
What if I am pulled over and suspected of driving under the influence?
Front-Line Video: An Interview with Jane Ellis, Anti-Bribery and Compliance Expert
A Moment of Simple Justice - Felony Everything
Understanding the Different Mandates Between Legal and Compliance February 3 2015
Investment Management Update - January 2015
Government's Health Care Fraud "Cash Cow" Keeps Mooing
Cullen & Dykman Sees Colleges Calling for Title IX Help v
What is a PBT? Do I have to cooperate?
BigLaw Recruiter: We Didn't Kill Dewey & LeBoeuf
On June 22, 2015, the US Attorney’s office for the Eastern District of Pennsylvania filed an information charging Adrian Rubin of Jenkintown, PA, with: (1) one count of conspiracy to violate RICO, 18 U.S.C. § 1962(d); (2) one...more
Stephanie Booker, Associate Director for Enforcement, Financial Crimes Enforcement Network (“FinCEN”), recently gave a speech at the Nevada Bar Association’s Bank Secrecy Act Conference in Las Vegas. Involved in the...more
Why it matters -
Three Financial Crimes Enforcement Network (FinCEN) orders, three sets of fines and asset forfeitures, a deferred prosecution agreement and one bank enforcement action demonstrate the resolve of the...more
On June 3, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a $75 million penalty against a Northern Mariana Islands casino for Bank Secrecy Act violations – the largest-ever FinCEN penalty assessed...more
The FCA has publicly announced an expectation that, in the context of managing money laundering risks, banks should not indiscriminately withdraw services from market sectors.
Brokers and asset managers with appropriate...more
On April 2, the DOJ announced a guilty plea by a Northern California real estate investor to charges of bid rigging and fraud conspiracy at foreclosure auctions in violation of the Sherman Act. The charges are the outcome of...more
The Federal Trade Commission (FTC) filed a complaint on February 19, seeking an injunction to prevent Sysco Corporation’s purchase of US Foods Inc. The FTC alleges that the deal would give Sysco too much market power in that...more
On January 21, 2015, the Supreme Court decided a narrow but important issue of appellate jurisdiction in cases that have been consolidated for pretrial proceedings by the Judicial Panel on Multidistrict Litigation. A...more
On November 19, the DOJ issued a press release announcing charges against six employees of a Georgia-based debt collection company for allegedly running a $4.1 million dollar debt collection scam. According to the press...more
This is the first in what we expect to be a series of updates on DOJ criminal actions in the cartel area. Here, we look at highlights over the last six months in the DOJ’s investigations of the auto parts industry, LIBOR, and...more
The U.S. Department of Justice (DOJ) recently made enforcement of the Foreign Corrupt Practices Act (FCPA) a top priority, second only to terrorism. While an overall increase in enforcement puts all industries on alert, the...more
On August 18, 2014, following a Department of Justice (DOJ) investigation and criminal indictment, Paul Robson became the second former Rabobank employee to plead guilty for his participation in a scheme to manipulate the...more
The Federal Trade Commission recently announced that it has entered into a settlement with one of the nation’s largest credit repair companies and its owners for alleged violations of the Credit Repair Organizations Act...more
I just downloaded and read the annual Cost of Compliance survey compiled by Thomson Reuters Accelus. It’s very interesting reading for those of us in the ethics and compliance industry. In my last blog post about the ERC...more
This month on the anticorruption front, a New York court orders two former Siemens executives to pay record civil penalties in a bribery case involving the company’s Argentina business; Canada prosecutes former executives...more
It’s the end of the world as we know it,It’s the end of the world as we know it,It’s the end of the world as we know it, and I feel fine -
The above lyrics came from REM and they reflect how I generally feel about law...more
Court’s application of statute of limitations will likely guide future conspiracy prosecutions.
On December 9, 2013, the Second Circuit Court of Appeals issued a 2-1 opinion reversing the conviction of three...more
The art of day-to-day internal investigations has been ignored in favor of media reports on high-profile, high-stakes internal investigations.
With the increasing threat of whistleblower complaints and increasing...more
UBS and Barclays Acknowledge Making False Libor Submissions. Investigations into misconduct at UBS and Barclays have revealed pervasive corruption of the London Interbank Offered Rate (“Libor”), which provides a benchmark for...more
One by one global banks are being ensnared in the LIBOR prosecution net.
Late last year UBS, the Swiss banking giant, entered into a massive settlement in which it agreed to pay approximately $1.5 billion in fines and...more
The end of the year was very tough for global banks. For months significant enforcement actions were expected in the ongoing LIBOR manipulation probe and anti-money laundering and sanctions violations probes....more
The holidays have come early for the Department of Justice’s Antitrust Division. The new fiscal year 2012 statistics for the Division’s accomplishments have been released. The statistics reveal that the Division’s criminal...more
The definitive guide to complying with the Foreign Corrupt Practices Act, written by those in charge of enforcing it: The Securities and Exchange Commission and the Department of Justice. From the SEC website:
Originally published in Corporate Crime, Fraud and Investigations multi-jurisdictional guide 2012/13 and is reproduced with the permission of the publisher, Practical Law Company.
- Regulatory provisions and...more
The LIBOR “scandal” could have far-reaching implications for financial institutions in the United States and global markets. It is hard to know exactly how the issue will play out. The Department of Justice is definitely...more
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