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Global Anti-Bribery Year-in-Review: 2015 Developments and Predictions for 2016

I. Introduction: Enforcement Trends and Priorities - Among other significant developments, 2015 saw the U.S. Department of Justice (the “DOJ” or the “Department”) document a policy priority of holding individuals...more

MLB Computer Hacking Scandal – The Intersection of Compliance and Cyber Security

Sorry but I have to begin this blog post with a short prescript on the passing of Glenn Frey. The Eagles were such a huge part of my teenage and college years that I am compelled to write about Glenn Frey and the band he...more

FIFA Ethics Committee Issues Eight-Year Bans to President and Vice President

On December 21, the FIFA Ethics Committee announced that it would ban its embattled President, Sepp Blatter, and Vice President, Michel Platini, from all football-related activities for eight years. The ban was imposed as a...more

FinCrimes Update - November 2015 Summary, Volume 2, Issue 9

FINCEN DIRECTOR HIGHLIGHTS THE SIGNIFICANCE OF SAR FILINGS - On December 9, FinCEN Director Calvery highlighted at a joint FBIIC-FSSCC meeting the role of FinCEN in gathering and analyzing financial intelligence and the...more

DOJ Charges 16 Additional Individuals with FIFA-Related Corruption; Swiss Authorities Arrest Two High-Ranking FIFA Members

On December 3, the DOJ charged an additional 16 individuals in connection with its ongoing corruption investigation into FIFA. The new indictment included a number of high ranking FIFA members, including Alfredo Hawit, the...more

Politics – The Invisible Force Behind China Artist and Art Market

After a period of significant growth from 2009 to 2014, the Chinese art market has experienced a drastic decline in the first half of 2015 with reports that the fine art auction turnover contracted at 30% less than the 2014...more

FIFA Investigation Ensnares President Blatter

After months of speculation about potential legal ramifications for FIFA President Joseph (“Sepp”) Blatter, the Office of the Attorney General of Switzerland announced that Mr. Blatter is the subject of criminal proceedings...more

Crime Doesn’t Pay (as much as it used to) – FBI Cracks Down on Trade of Looted Syrian and Iraqi Cultural Artifacts

In support of the international crackdown on the black market trade of looted cultural artifacts, the FBI recently announced that art dealers may be prosecuted for engaging in the trade of stolen Iraqi and Syrian antiquities....more

Red Notice Newsletter - June 2015

This month on the anticorruption front, an energy company announces the U.S. Department of Justice (DOJ) has declined to bring charges following an Foreign Corrupt Practices Act (FCPA)-related investigation, the protracted...more

Corporate Investigations & White Collar Defense - June 2015

The Unfolding FIFA Scandal: Will the DOJ Show the Banks a Red Card? - Why it matters: The worldwide soccer community has for years decried the brazen corruption that permeated FIFA, international soccer’s governing...more

FIFA Investigation Updates: Plea Agreement with American FIFA Official Unsealed

On June 15, the U.S. District Court for the Southern District of New York unsealed a 2013 plea agreement under which American FIFA Executive Committee Member Chuck Blazer secretly pleaded guilty to ten charges related to...more

Foreign Corrupt Practice Act Update

Recent criminal indictments of FIFA officials should remind businesses to review their obligations under the Foreign Corrupt Practices Act (FCPA). Those who violate the FCPA can face civil and criminal penalties, including...more

Like a Rolling Stone and Charitable Donations Under the FCPA

Today we celebrate one of the seminal achievements in rock and roll for it was on this day, 50 years ago, in 1965 that Bob Dylan recorded his single Like a Rolling Stone. Columbia Records executives initially rejected the...more

FIFA and BHP Billiton: The Unique FCPA Challenges Present in International Sports

Recent enforcement actions by the Department of Justice and Securities and Exchange Commission have raised the profile of corruption in international sport and highlight unique FCPA compliance concerns. This note will explain...more

INTERPOL suspends FIFA donation funds, but what happens to the money now, and what happens to INTERPOL?

Last week, I addressed INTERPOL’s listing of several individuals who are wanted for prosecution by the United States for FIFA-related financial crimes. That post is here. In light of those listings, RNLJ requested...more

The FIFA Prosecution & the Strategy Behind the Federal Criminal Indictment

On May 27, 2015 the United States Department of Justice unsealed several charging documents involving the Federation Internationale de Football Association (“FIFA”). These documents included four Bills of Information, each...more

Why Should Americans Care About the FIFA Indictments? Part IV – Corruption is a Global Scourge

Today, I conclude my four-part series on the above question posed to me recently by a colleague. In Part I, I responded that only the US government had the wherewithal and will to do so and that it continued the...more

FIFA and INTERPOL, together again- U.S. charges FIFA officials and obtains Red Notices against them

Unless you’ve been living under a rock, you probably know that FIFA has been dealing with a scandal lately: the U.S. government has charged multiple individuals with ties to FIFA with expansive criminal violations, and...more

Top Ten International Anti-Corruption Developments for May 2015

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month with links to primary...more

Why Should Americans Care About the FIFA Indictments? Part III – Corruption and US Companies

Today, I continue my four-part series on the above question posed to me recently by a colleague. In Part I, I wrote that only the US government had the wherewithal, tools and will to do so. Yesterday, I focused on corruption...more

FIFA Investigation Updates: President Resigns Amidst Corruption Probe; Interpol Issues Red Notices For Six

On June 2, continuing the fallout from the racketeering, wire fraud, and money laundering indictments announced last week by DOJ against soccer executives at FIFA and others tied to the organization, FIFA President Sepp...more

Why Should Americans Care About the FIFA Indictments? Part II – Corruption Changes the Truth of the Game

Today, I continue my (now) four-part series on the above question posed to me recently by a colleague. (I know I wrote that it would be a three-part series but as usual I got carried away when I started writing.) Yesterday, I...more

FinCrimes Update - May 2015 Supplement

FEDERAL RESERVE ORDERS TWO FINANCIAL INSTITUTIONS TO IMPROVE BSA/AML COMPLIANCE PROGRAMS - On June 1, a Boston-based international financial services holding company and its banking subsidiary agreed to improve...more

FinCrimes Update - May 2015 Summary, Volume 2, Issue 5

FINCEN NAMES JAMES EL-HINDI AS NEW DEPUTY DIRECTOR - On May 21, FinCEN announced Jamal El-Hindi as its new Deputy Director. Since January 2015, El-Hindi has been serving as the agency’s acting Deputy Director, and...more

U.S. Justice Department v. FIFA Executives and Others in Bribery Indictment

In an ironic twist, the U.S. Justice Department unsealed a 47-count indictment yesterday charging nine present and former officials of the Federation Internationale de Football Association (better known by its acronym, FIFA)...more

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