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Monaco-Based Company Alleges Extortion Following Media Reports of Mass Bribery

On May 16, a Monaco-based industrial solutions company released a statement denying claims made in a media report that linked the company to allegations of bribing foreign government officials to secure contracts within the...more

Swiss Extradite Final FIFA Official Arrested in May 2015 Sweep

On May 18, former President of the Nicaraguan Football Federal Julio Rocha was extradited from Switzerland to the United States. He was the final FIFA official to be extradited following the arrests made in Zurich in May...more

DOJ Sentences Founder of Money Laundering Operation to 20 Years Imprisonment

On May 6, the DOJ announced that U.S. District Judge Denise L. Cote sentenced the founder of a Costa Rica-based virtual currency company to 20 years imprisonment and ordered him to pay a $500,000 fine for charges related to...more

SEC Charges State Street Employee For Fraudulent Fees

Transition Management is a service offered by securities professionals to pension funds and other investment managers who are changing fund managers, investment managers or making similar transitions and need to make...more

"FinCEN Finalizes Customer Due Diligence Rule Amid Other Actions to Enhance Financial Transparency"

In the wake of the Panama Papers controversy, the U.S. government has taken major steps this month to promote financial transparency. First, the Financial Crimes Enforcement Network (FinCEN) finalized its proposed rule issued...more

FinCrimes Update - April 2016 Summary, Volume 4, Issue 4

AML/BSA & OFAC: FINCEN ANNOUNCES DEPARTURE OF DIRECTOR CALVERY - On April 26, FinCEN announced the departure of Director Calvery. Commenting on Calvery’s accomplishments during her tenure as Director, the agency...more

Tackling a Panamanian Money Laundering Organization: OFAC Sanctions the Waked Money Laundering Organization, Colombia Arrests the...

OFAC Sanctions - On May 5, 2016, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) announced sanctions against 77 entities and individuals associated with the Waked Money Laundering Organization...more

The Panama Papers: Are You at Risk?

The recent document breach of unprecedented size (2.6 terabytes) from the Panamanian law firm Mossack Fonseca—known as “The Panama Papers”—poses various significant risks to corporations, private organizations, individual...more

Are new Government AML/CTF proposals a step too far?

On 21 April 2016, the Government released its new Action Plan for anti-money laundering (AML) and counter-terrorist finance (CTF). The Action Plan contains a number of AML/CTF proposals on which the UK Government wishes to...more

Panama Papers: Prosecutors Launch Investigations

When a scandal hits the media like the Panama Papers leak of 11.5 million confidential legal records, we all know what to expect. Criminal investigations, regulatory responses, and of course, congressional hearings of some...more

This Week In Securities Litigation

The Commission prevailed at trial this week, securing a favorable verdict after a two week jury trial. The action centered on false statements made by an executive regarding regulatory approvals for the only drug of the...more

Court orders, conspiracies and the long arm of the English courts

Overseas banks beware as the tort of unlawful means conspiracy could open up new ways of punishing those who aid defendants aiming to evade freezing orders....more

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

New UK AML Action Plan – The Increased Role of the Private Sector

The UK Government has just published an Action Plan setting out extensive reform to the anti-money laundering ("AML") and counter-financing of terrorism ("CFT") regime and in particular the filing of Suspicious Activity...more

Dorsey Anti-Corruption Digest - April 2016

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...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

A transatlantic consideration of recent developments in corporate self-reporting

More carrot, less stick? On 5 April 2016, the Fraud Section of the US Department of Justice’s (DOJ) Criminal Division issued an Enforcement Plan and Guidance (the DOJ Guidance), setting out the steps that it is taking to...more

As Panama Papers Illustrates, IRS Discovery of Undisclosed Assets Just a Matter of Time

As the recent leak of the "Panama Papers" reminded the world, some secrets don't keep well, particularly those related to undisclosed foreign assets. And once a person's identity is disclosed as a holder of undisclosed...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

Forex Investment Scheme Results in Criminal Charges

Investment fund fraud and Ponzi schemes have become a staple of SEC enforcement. The investment fraud schemes often cross from securities into other areas such as the currency markets. In such instances either the CFTC or the...more

Second Circuit To Determine Whether Artful Pleading Can Extend FCPA Jurisdiction

Prosecutors in the District of Connecticut have appealed a district court’s ruling that conspiracy and aiding and abetting charges cannot be used to extend the FCPA’s jurisdictional reach. The FCPA has three...more

European Banking Authority Opinion on Customer Due Diligence for Asylum Seekers

The European Banking Authority published an Opinion on the application of customer due diligence measures to customers who are asylum seekers from higher-risk third countries or territories. The Opinion, addressed to national...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

Foreign Financial Institutions Beware: United States Expands Economic Sanctions Against Hizballah

Effective April 16, 2016, the United States will implement sanctions pursuant to the Hizballah International Financing Prevention Act of 2015. The new sanctions target Hizballah (or Hezbollah) and non-U.S. persons who support...more

New FCPA Self-Reporting Pilot Program Formalizes Rewards but Relies on Discretionary Implementation

On April 5, 2016, the Department of Justice unveiled a one-year pilot program designed to encourage companies to self-report violations of the Foreign Corrupt Practices Act (the FCPA). Built upon the Department’s September 9,...more

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