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Canadian Government Steps Up Enforcement of Economic Sanctions - Conviction under Special Economic Measures Act for attempted...

For the first time in over 20 years since the enactment of the Special Economic Measures Act (SEMA), an Alberta-based company was charged with violating this statute by attempting to export controlled goods valued at $15 to...more

Offshore Accounts? IRS is Watching

If you have unreported income from offshore accounts, now may be the best time to come forward and report those earnings; otherwise, you may be susceptible to criminal prosecution. The IRS initially began this...more

Financial Regulatory Developments Focus - April 2014

In this issue: - Derivatives - Compensation - Regulatory Capital - Financial Services - Financial Crime - Excerpt from Derivatives: European Commission Consults on Definition...more

Warning signs of Red Notice Abuse Based on Private Disputes

In the last post, I addressed the issue of INTERPOL's involvement in financial disputes arising from debts owed by individuals to financial institutions in the UAE. Today, the focus expands to the broader question of how some...more

Casino AML Compliance Update: Las Vegas Sands Corp. Places Macau Casino Junkets Under Increased Scrutiny.

On April 4, 2014, Bloomberg reported that the Las Vegas Sands Corp. (“Sands”) has increased its scrutiny of casino junket operators in Macau. The decision comes as casinos seek to meet the increased demands of federal...more

INTERPOL Red Notices - Update on Bankers' Use of INTERPOL's Tools to Enforce Private Debts

The UAE banking crisis and its inappropriate involvement with INTERPOL Red Notices, which have been addressed here and here in this blog, appears to drag on still. Parag Deulgaonkar reported recently for Emirates 24/7 that...more

FinCEN Issues Advisory Regarding the FATF’s Updated List of Jurisdictions with AML/CTF Strategic Deficiencies

FinCEN issued an advisory (the “Advisory”) regarding the issuance by the Financial Action Task Force (the “FATF”) of an updated list of jurisdictions that the FATF has identified as having strategic deficiencies in their...more

Battuta D'arresto Per La Voluntary Disclosure

Come annunciato, l'articolo 1 del decreto legge 28 gennaio 2014, n. 4 (pubblicato in G.U. n. 23 del 29 gennaio 2014 – di seguito "Decreto") in materia di "Voluntary Disclosure" o "Collaborazione Volontaria" per il rientro dei...more

Bitcoin - Calls for Regulation - Part Eight

“Virtual currencies”, and bitcoin in particular, continued to attract a lot of attention. The sudden shutdowns of Mt. Gox (Japan), a large bitcoin exchange, and Flexcoin (Canada), a bitcoin bank, led to renewed and...more

Allegations Of Collusion Among Financial Institutions—Where We’ve Been, Where We Are, What We’ve Learned

Over the last 15 years, financial institutions have paid billions of dollars to settle claims that they colluded with each other. Below, we discuss four separate matters, beginning with the Nasdaq spread cases in the late...more

DOJ and SEC Representatives Tackle Pressing Anti-Corruption Issues in 2014

On March 20th and 21st, U.S. regulators, practioners, and other anti-corruption industry professionals gathered in Washington, D.C. for the Second Annual Global Anti-Corruption Congress. The Congress featured speakers,...more

Emphasis On Enforcement

In back-to-back keynote addresses Monday to the Securities & Financial Markets Association’s annual Compliance & Legal meeting, SEC-Chair Mary Jo White and Southern District of New York US Attorney Preet Bharara renewed the...more

Levin and McCain Urge DOJ to Seek Extradition of Fugitive Swiss Bankers

Bloomberg news reports that on March 18, 2014, U.S. Senators Carl Levin and John McCain wrote a letter urging the Justice Department to seek extradition of about 30 Swiss bankers and others who are charged with enabling...more

UPDATE: Developments in the Ukraine and Impact on Investments

On Sunday, Crimea voted to secede from Ukraine. The EU and U.S., which consider Sunday’s referendum in Crimea to be illegal, retaliated with sanctions. The nature of these is set out below as a further update to the Alert...more

Council of the EU Presidency Compromise Proposal on MLD4

On March 3, the Council of the EU published a compromise proposal (dated January 28, 2014) on the European Commission’s proposed Directive on the prevention of the use of the financial system for the purpose of money...more

Survey: 28 Reasons Why The Typical Compliance Officer’s Week Leaves Dangerously Little Time for Corporate Ethics Training

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

Red Notice Newsletter - March 2014

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

The risk of self-incrimination in cross-border disputes: The use of Canadian discovery evidence in United States...

Royal Trust Corporation of Canada v. Fisherman (“Royal Trust”), a decision of the Ontario Superior Court, is another example of a court addressing the risk that discovery evidence could be used against a defendant in a...more

Bitcoin - Turbulent Waters - Part Seven

“Virtual currencies”, and bitcoin in particular, continued to attract a lot of attention. The sudden demise of Mt. Gox (Japan), one of the largest bitcoin exchanges, adds to the mystery and mistrust surrounding the virtual...more

Update: U.S. International Tax Enforcement Efforts

On February 25, 2014 the U.S. Senate Permanent Subcommittee on Investigations, issued its report on its investigation into offshore tax evasion and the participation of Swiss Banks. Specific recommendations were made, among...more

UK’s Serious Fraud Office Looks to Pursue More Prosecutions of Corporates

A proposed amendment to the UK Bribery Act would give the SFO greater power to prosecute corporates for financial crimes committed by their employees. The head of the UK’s Serious Fraud Office (SFO), David Green,...more

Senate Hearing Takes Aim on Offshore Tax Evasion

Today, February 26, 2014, the Senate Permanent Subcommittee on Investigations will hold a hearing on offshore tax evasion titled “Offshore Tax Evasion: The Effort to Collect Unpaid Taxes on Billions in Hidden Offshore...more

Today Deferred Prosecution Agreements (“DPAs”) come into force in the UK

DPAs are agreements between prosecutors and corporate organisations that charges will be presented but not pursued, provided the organisation complies with a set of agreed terms and conditions. Those terms and conditions...more

C’Mon Man Or The End Of The World?

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

Financial Regulatory Developments Focus - February 18, 2014

In this issue: - Derivatives - Regulatory Capital - Financial Services - Enforcement - Events - People - Excerpt from Derivatives - ESMA Requests Clarification on...more

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