On February 23, three climate advocacy groups—Friends of the Earth France, Notre Affaire à Tous and Oxfam France—filed a lawsuit alleging that a global financial institution violated Article L. 225-102-4.-I of the French...more
On February 7, a group of 30 investors, representing over $1.5 trillion of assets under management, wrote to the CEOs and board chairs of five major European banks “urging them to stop directly financing new oil and gas...more
The Financial Industry Regulatory Authority is not known for its aggressive enforcement record. But that may be changing. FINRA recently fined BNP Paribas for $15 million for anti-money laundering deficiencies in the...more
With Davos 2018 in the rear view mirror, some analysts are pegging the “geopolitical momentum” as China’s to claim, thanks in no small part to its expansive and ongoing “Belt and Road” initiative....more
Several members of healthcare hedge fund Deerfield Mgmt have been implicated in an insider-trading case over the alleged use of confidential information about gov’t financing to trade shares in affected health care companies....more
Charles Schwab Fined US $2 Million by FINRA for Net Capital Deficiencies: Charles Schwab & Co. agreed to pay US $2 million to the Financial Industry Regulatory Authority to resolve allegations that it had net capital...more
On April 2, 2015, plaintiffs BNP Paribas Mortgage Corporation and BNP Paribas and defendant Bank of America filed a Joint Stipulation of Dismissal with Prejudice stating that both parties had reached an agreement to settle...more
Global banks are caught in US prosecutor’s cross hairs. Not only do they have to worry about basic AML compliance and enforcement, they now have major risks in sanctions compliance. For some inexplicable reasons, global...more
Former Goldman Sachs, Morgan Stanley, BNP Paribas and Societe Generale bankers have announced a new futures and options derivatives-trading platform for bitcoin. The derivatives, tied to the price of bitcoin, will enable...more
The penalties for compliance missteps have never been higher — particularly in the international regulatory context. As the record-setting penalties against BNP Paribas (nearly $9 billion in penalties for violations of...more
In what is becoming an annual refrain, 2014 marked another year of robust False Claims Act (FCA) enforcement by the U.S. Department of Justice (DOJ) and mushrooming qui tam lawsuits by whistleblowers. Indeed, fiscal year 2014...more
If there is one industry that needs an ethics overhaul, it has to be the financial industry. The list of transgressions continues to grow – AML/sanctions, LIBOR, Foreign Exchange Currency Cartels and Market Manipulations,...more
On October 23, the Second Circuit Court of Appeals issued a decision in Mastafa v. Chevron Corp., a case filed against Chevron Corp. and BNP Paribas pursuant to the Alien Tort Statute (“ATS”). The court upheld the District...more
Marshall Miller, the Justice Department’s principal Deputy Assistant Attorney General for the Criminal Division, has been heating up the compliance conference circuit in recent weeks. On September 17th, it was the Global...more
Recently, Attorney General Holder and DAAG Marshall Miller from the Criminal Division delivered important speeches on the Justice Department’s initiative to increase individual criminal prosecutions....more
Welcome to the July 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, two Noble Corporation executives settle with the U.S. Securities and Exchange...more
BNP Paribas’ recent settlement of nearly $9 billion for violating US Sanctions against Sudan, Iran and other countries is another important achievement for the US Attorney’s Office in the Southern District of New York and the...more
The $963 million settlement OFAC recently reached with French banking giant BNP Paribas SA (BNP) was both the largest OFAC settlement to date and represents only a small fraction of the nearly $9 billion in total fines...more
On June 30, 2014, BNP Paribas SA (“BNPP”), the largest bank in France, pled guilty to conspiring to violate U.S. sanctions laws and agreed to pay a total of nearly $8.9 billion in criminal forfeiture and penalties to the U.S....more
I will start by saying I am a proud Francophile. I love many things about French culture; from the just-right draw of their espresso (sorry, Italy, that ristretto is just too short and bitter) to the sacrosanct treatment of...more
With all the attention to Anti-Money Laundering and Bank Secrecy Act enforcement, I thought it would be a good time to review some basic AML ethics and compliance principles....more