International Trade Administrative Agency Criminal Law

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U.S. Government Announces Significant Sanctions Enforcement Actions Against Schlumberger and PayPal

The U.S. Government announced two major sanctions enforcement actions this week that reinforce the compliance challenges faced by both U.S. companies with international activities and non-U.S. companies subject to U.S....more

Alert: Recovering the Proceeds of Corruption: How States Can Recover Stolen Assets

Cooley discusses the legal options open to states seeking to locate, freeze and recover the proceeds of corruption laundered to foreign states, and considers their advantages and disadvantages. Corruption cases are...more

FinCEN Issues Notice of Proposed Rulemaking on Andorran Bank as “Primary Money Laundering Concern”

On March 10, 2015, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) named Banca Privada d’Andorra (BPA) a foreign financial institution of “primary money laundering concern,” a measure that will...more

OSC Affirms Breadth of Inter-Jurisdictional Enforcement Power, Limits on Sanctions in Conrad Black Case

The recent decision in Re Conrad M. Black et al. illustrates how the Ontario Securities Commission (OSC) will use its inter-jurisdictional enforcement authority to impose sanctions relating to conduct in other jurisdictions...more

International Fraud & Asset Tracing (3rd Edition), United States

In this Guide: - Introduction - Managing the Internal Investigation - Disclosure from Third Parties - Steps to Preserve Assets/Documents - Civil Proceedings - Anti-Bribery/Anti-Corruption Legislation -...more

New Anti-Trafficking Rule Presents Significant Challenges for Government Contractors

Effective today, a new Anti-Trafficking rule will substantially change and increase federal contractors’ compliance and certification requirements. ...more

This Week In Securities Litigation

Four SEC Commissioners addressed the annual SEC Speaks Conference, reviewing recent agency initiatives and tracing potential paths for the future. The SEC also brought another FCPA action, a misappropriation case and an...more

OECD Slams France for Lacklustre Bribery & Corruption Enforcement

International pressure is mounting for France to boost their anti-bribery and corruption efforts, but French organisations face the most serious risks—and have the greatest need for strong compliance programmes—today....more

UK Home Affairs Committee – Evaluating the National Crime Agency

On 17 February, the House of Commons Home Affairs Committee published its report on the architecture of policing in the United Kingdom. This report follows a period of five years of restructuring and reshaping policing at the...more

This Week In Securities Litigation

The Commission resolved its actions against the PRC based affiliates of five major accounting firms for failure to produce audit work papers. The settlement contains a series of procedures designed to facilitate production in...more

INTERPOL’s CCF increases its sessions for 2015- an encouraging sign

It appears that one of the first orders of business upon Nina Vajic‘s assuming her post as Chair of the Commission for the Control of INTERPOL’s Files (CCF) was to increase the number of scheduled sessions for the year....more

DOJ Announces First FCPA Enforcement Action of 2015

Last week, the Department of Justice announced the first Foreign Corrupt Practices Act enforcement action of 2015, against Dmitrij Harder, the former owner and president of the Chestnut Consulting Group. The allegations are...more

This Week In Securities Litigation

FCPA enforcement was the focus this first week of the new year. The DOJ brought FCPA and Travel Act charges against an individual alleged to have repeatedly bribed an official of the European Bank of Reconstruction and...more

Alstom Joins Santa’s Naughty List – In a Very Big Way

The North Pole for Foreign Corrupt Practices Act (FCPA) enforcement action announcements seems to have temporarily moved south for the month of December. Last week there was the final announcement of the long-standing Avon...more

A new leader for the Commission for the Control of INTERPOL’s Files

INTERPOL has a new Chairperson for the Commission for the Control of INTERPOL’s Files, which is the quasi-appellate arm of the organization. Nina Vajic assumed her new post as Chairperson in September....more

This Week In Securities Litigation

The Commission brought a series of administrative proceedings this week and one civil injunctive action. The civil injunctive action was an insider trading case. The administrative proceedings centered on FCPA violations, the...more

Stacking the Deck: SEC’s Use of Administrative Proceedings

The SEC has a real perception problem. They cannot win in court. Whether this is fair or not, the SEC needs to move beyond this fear of losing since it only undermines the integrity of its enforcement program....more

Administrative and criminal violations involving the same fact: the recent positions of the European Court of Human Rights and of...

The European Court of Human Rights takes a stand on the ne bis in idem principle intervening on the relationship between administrative and criminal violations involving identical facts. Two recent decisions give interesting...more

"SEC Judge Issues Initial Decision Regarding Chinese Affiliates of the Big Four Accounting Firms"

On January 22, 2014, U.S. Securities and Exchange Commission Administrative Law Judge Cameron Elliot (the ALJ) issued an initial decision censuring the Chinese accounting firms affiliated with Ernst & Young LLP, KPMG LLP...more

Corporate Compliance Policies – Interview with Bridget Rohde, Member, Mintz Levin [Video]

Attorney Bridget Rohde, Member of Mintz Levin's Litigation Practice, discusses the importance of comprehensive corporate compliance policies....more

United States of America v. Ross William Ulbricht

Federal indictment against Silk Road founder Ross Ulbricht for narcotics trafficking, computer hacking, and money laundering

Full text copy of the federal indictment filed September 27, 2013 against Silk Road founder Ross Ulbricht – aka Dread Pirate Roberts, DPR, and Silk Road – for narcotics trafficking, computer hacking, and money laundering (the...more

"Ranbaxy Resolves Criminal and Civil Charges Through Record Settlement"

Executive Summary - On May 13, 2013, generic drug manufacturer Ranbaxy USA Inc. (Ranbaxy), a subsidiary of Indian generic drug manufacturer Ranbaxy Laboratories Limited, pled guilty to seven felony charges as part of a...more

Two Recent FCPA Cases Highlight The Critical Importance Of A Company's Response To The Discovery Of Misconduct Within Its Ranks

How critical is a company's response to the discovery of misconduct within its ranks? Two recent developments in the world of Foreign Corrupt Practices Act ("FCPA") enforcement show that a company's response can make the...more

Commerce Takes A More Aggressive Stance On Fraud by Jef Denning

In the March 2011 edition edition of the Trade and Manufacturing Alert, we reported on the decision by the United States Court of Appeals for the Federal Circuit in Home Products Int’l v. United States, 633 F.3d 1369 (2011),...more

Justice Department and SEC Issue Guidance on Anti-Bribery Law

Originally published in Swampfox - January 22, 2013. In November 2012 the Department of Justice and the Securities and Exchange Commission issued a 120-page “resource guide” to the U.S. Foreign Corrupt Practices Act. ...more

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