Corruption Risks in the Middle East by Michael Volkov on 5/23/2012 The Middle East is a diverse area with significant disparities in the region. Oil and gas dominate the economies. Cultural and economic factors make compliance extremely difficult in the Middle East. Interestingly, on...more
Federal Bank Secrecy Act Issues for Mobile Payment Systems by Davis Wright Tremaine LLP on 5/23/2012 In This Presentation: - The BSA from 30,000 Feet - ABCs of the BSA for MSBs - Impact on Customer Acquisition - BSA/AML Enforcement - Current Topics and Resources Excerpt from The BSA from 30,000...more
How INTERPOL's CCF Can Reduce Its Backlog and Become More Efficient by The Law Office of Michelle A. Estlund, P.A. on 5/23/2012 In the last post, we addressed the fact that the Commission for the Control of INTERPOL's Files (CCF) is still required under its operating rules to meet only three times per year. This requirement has remained the same in...more
FSA Fines Martin Currie £3.5 million for Conflict of Interests Failures by Katten Muchin Rosenman LLP on 5/22/2012 On May 10, the UK Financial Services Authority (FSA) announced that it fined Martin Currie Investment Management Limited and Martin Currie Inc (together, Martin Currie) £3.5 million (approximately $5.5 million) for conflict...more
Sanctions Enforcement — An Increasing Risk by Michael Volkov on 5/22/2012 Everyone writes about the FCPA and the UK Bribery Act. Some are more willing to tackle export compliance. Given the Obama Administration’s reliance on sanctions as a foreign policy tool, companies need to address the...more
FSA Fines Habib Bank and its Money Laundering Reporting Officer for AML Control Failings by Katten Muchin Rosenman LLP on 5/22/2012 On May 15, the UK Financial Services Authority (FSA) announced that it had fined Habib Bank AG Zurich (Habib Bank) £525,000 (approximately $830,000) and Syed Itrat Hussain (Hussain) its former Money Laundering Reporting...more
Remarks delivered to The International Human Rights Framework Opportunities for Attorneys and Advocates, "The Role of Lawyers in... by K&L Gates LLP on 5/22/2012 Good morning. I am very pleased to be here with you, and I thank the International Justice Resource Center for inviting me to share some thoughts on a subject that is close to my heart. My thanks go also to the co-organizers...more
Archer Daniels Midland Price-Fixing Video from “Fair Fight in the Marketplace” by Howard Ullman on 5/21/2012 I recently stumbled upon this YouTube video from “Fair Fight in the Marketplace.” This segment shows the real story of the Archer Daniels Midland (ADM) price-fixing case, the basis for the movie “The Informant!“, and...more
Nightmare Scenarios for an Internal Investigation by Michael Volkov on 5/21/2012 Everyone has tips on how to conduct internal investigations. The how-to articles present advice on how to conduct an internal investigation. Unfortunately, the reality is far more complex and risky. Behind many of the...more
Ministry of Justice Seeks Consultation on the Introduction of Deferred Prosecution Agreements in the UK by Bryan Cave on 5/21/2012 The Ministry of Justice yesterday initiated a consultation process following its proposal to introduce Deferred Prosecution Agreements (DPAs) in the United Kingdom as an enforcement tool to combat economic crimes by...more
INTERPOL's Grievance Process: Time for a Full-Time Commission? by The Law Office of Michelle A. Estlund, P.A. on 5/21/2012 The process for seeking relief from an improperly issued Red Notice currently requires that the request be reviewed by the Commission for the Control of INTERPOL's Files. The Commission is made up of five individuals from...more
UK Bribery Act – There's a New Constable in Town by Pillsbury Winthrop Shaw Pittman LLP on 5/17/2012 Directorship of the UK Serious Fraud Office ("SFO") passed this month to David Green QC. Mr. Green joins the SFO from private practice, where he was a barrister specializing in serious crime. He also previously served as the...more
Championing the UK Bribery Act: The 2012 Olympic Games and Corporate Hospitality by McDermott Will & Emery on 5/17/2012 Since it came into force on 1 July 2011, the impact of the UK Bribery Act 2010 (the Act) on the giving of corporate hospitality, gifts and other expenses has raised concerns among those who fall under the Act’s jurisdiction. ...more
A Man Overboard Will Not Sink the Ship: How Robust FCPA Compliance Can Keep a Company Out of Hot Water Even When An Executive is... by Sheppard Mullin Richter & Hampton LLP on 5/17/2012 The story of one man prosecuted by the SEC and the DOJ for an FCPA violation may run a little below the radar these days, when allegations of bribery by manufacturing, retail, and entertainment companies plaster the...more
Switzerland Responds to Wegelin Indictment and DOJ’s Relentless Pursuit of Offshore Bank Account Information by Sheppard Mullin Richter & Hampton LLP on 5/16/2012 On February 2, 2012, Wegelin & Co., Switzerland’s oldest private bank, became the first overseas bank to be indicted by the United States for aiding tax fraud—but it may not be the last. The company is one of at least 11...more