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Private Equity and the Och-Ziff Enforcement Action

Since 2010, the Justice Department and the SEC have been “investigating” a number of private equity and hedge funds for FCPA violations. The launch of the inquiries was a big deal with lots of fanfare and focus on private...more

In Case You Missed It: Launch Links - April 2016 #4

Some interesting links we found across the web this week: - House of Representatives approves bill requiring warrants for email searches - It was a productive week on the Hill, as the House passed the Email...more

The Panama Effect: UK Government accelerates proposals to criminalise failure to prevent tax evasion

10 considerations for professionals and corporates worldwide in advance of the new law. Overview - In a move widely seen as a response to the so-called “Panama Papers” revelations, the UK Government has enhanced...more

French Anti-Corruption Reform Expected In 2016

France to introduce significant changes affecting large companies and top management, to improve current anti-bribery system. The French Parliament is expected to enact “Sapin II” on transparency, anti-corruption and...more

New Business Opportunities in Iran! Who Will Be Your Banker? Non-U.S. Banks Hesitant to Process Lawful Iran Transactions…and for...

- Sanctions relief presents new business opportunities with Iran - Most U.S. companies are still prohibited from Iran business, but the U.S. government is encouraging lawful business by non-U.S. companies - The...more

FinCrimes Update - February 2016 Summary, Volume 4, Issue 2

OCC AND FINCEN ASSESS CIVIL MONEY PENALTIES AGAINST FLORIDA-BASED WEALTH MANAGEMENT FIRM FOR BSA VIOLATIONS - On February 25, the OCC, in coordination with FinCEN, announced that it took action against a Florida-based...more

Sharper Teeth For Sanctions Enforcement?

The current UK sanctions enforcement regime is a complicated web reflecting the requirements of UN Security Council Regulations, EU Regulations, and UK Primary and Secondary Legislation. Penalties for breaches of sanctions...more

UK Financial Sanctions Enforcement – New Powers and Tougher Sentences

The UK Government put a package of proposals to Parliament in February to increase both the type and the potential severity of consequences for persons and companies who breach EU financial sanctions. If approved, these...more

A "French Bribery (and Sunshine) Act" is about to be launched - a legal revolution is underway in France

France has been for a long time lagging behind on the field of anti-corruption laws. In 2012, the Organisation for Economic Co-operation and Development raised serious concerns regarding the lack of bribery convictions in...more

Cash for Scalps: Governor Cuomo Announces New Round of Grants for Tax Prosecutions

Last week, Governor Cuomo announced the latest round of grants to district attorneys’ offices in 29 New York State counties under the Crimes Against Revenue Program (also known as “CARP”). The program provides substantial...more

Africa Update - November 2015 #2

Leading the News: Egypt - On November 5th, U.S. President Barack Obama expressed his belief it was possible there was a bomb on board the Russian passenger jet that went down in Egypt’s Sinai Peninsula last week....more

DOJ’s first prosecution for campaign finance coordination — a sign of things to come?

With the 2016 presidential campaign in full swing, pundits, reformers and the media are once again shining a light on the role of independent-expenditure-only committees, aka “super PACs,” in the American political process....more

The Political Implications Of UK's Tom Hayes Verdict

On Monday, Aug. 3, Tom Hayes was convicted and sentenced to 14 years of imprisonment for his part in the manipulation of the London Interbank Offered Rate (Libor). The result has attracted attention because it was the first...more

Africa Update - July 2015 #2

In This Issue: - Leading the News - United States – Africa Relations - North Africa - East Africa - West Africa - Sub-Saharan Africa - General Africa News - Excerpt from Leading the...more

Campaign Coordination: Warning to Political Candidates and Related Super PACs

Tyler Harber’s prosecution, and the two year federal prison sentence he recently received, are clearly warning shots across the bow of federal political campaigns around the country. And the blatant and unsympathetic nature...more

"Department of Justice Secures Sentence in First Super PAC Coordination Case"

The Department of Justice recently concluded its first criminal prosecution of coordination between an independent-expenditure-only committee (super PAC) and a campaign committee. On June 12, 2015, the U.S. District Court for...more

Structuring Trips Up Speaker Hastert

Former Speaker of the United States House of Representatives Dennis Hastert entered the well of a courtroom in the Northern District of Illinois earlier this week to enter a plea of not guilty to charges that he structured...more

FinCrimes Update - April 2015 Summary, Volume 2, Issue 4

OFAC FINES PAYMENT PROCESSING COMPANY FOR PROVIDING SERVICES TO A DESIGNATED NARCOTICS TRAFFICKER - On April 15, OFAC entered into a $23,336 settlement with an Atlanta-based payment processing company for its role in...more

EU: new AML rules approved by the Council of Europe

On 20 April 2015, the Council of Europe adopted its position at the first reading on new rules aimed at preventing money laundering and terrorist financing. This is the part of the final stages of the passage of what will...more

"Facilitation": A New Tool for Extraterritorial Sanctions Enforcement?

Recent OFAC and DOJ actions have focused on certain entities – overseas financial institutions – and particular conduct – US dollar clearing and associated “stripping.” The DOJ’s recent $232 million settlement and negotiated...more

South Carolina Legislative Update

The House of Representatives was on recess this week and the South Carolina Senate had an abbreviated week and met on Tuesday and Wednesday. The Senate approved and sent to the House several measures, including...more

More Cases Alleging Illegal Coordination Efforts Could be on the Horizon

In light of the first federal “coordination” case guilty plea, the Department of Justice (“DOJ”) has announced its intent to aggressively pursue convictions for coordination violations. This apparently new focus comes as the...more

Trade & Manufacturing - March 2015

In This Issue: - Foreign Currency Manipulation Front and Center in U.S. Trade Talks - United States Challenges Chinese Export Subsidies at the WTO - Executive Branch Launches Plan to Combat Wildlife...more

Guilty Plea in DOJ’s First Criminal Prosecution for Campaign Finance Coordination

The news media has already engaged in rampant speculation regarding the potential candidates from both parties in the 2016 presidential election. Inextricably tied to the talk of political campaigns is the public discussion...more

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

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