News & Analysis as of

Compliance Department of Justice (DOJ) Banking Sector

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
ArentFox Schiff

Investigations Newsletter: Deputy Attorney General Monaco Warns Industries: “Fraud Using AI is Still Fraud”

ArentFox Schiff on

On March 7, Deputy Attorney General Lisa Monaco delivered the keynote remarks at the American Bar Association’s (ABA) 39th National Institute on White Collar Crime. She noted that artificial intelligence (AI) “holds great...more

Skadden, Arps, Slate, Meagher & Flom LLP

Key Takeaways From Danske Bank’s Settlement of DOJ and SEC Fraud Charges Over Its Anti-Money Laundering Compliance

On December 13, 2022, Danske Bank A/S, headquartered in Denmark, pled guilty to one count of conspiracy to commit bank fraud (18 U.S.C. § 1349) and agreed to forfeit approximately $2.06 billion to resolve an investigation by...more

Venable LLP

Marijuana Banking in 2022: Lessons Learned and Best Practices

Venable LLP on

​​​​​​​As we pass the halfway mark of 2022, it's a good time to reflect on what has happened, or not happened, with respect to the legal framework for the provision of financial services to marijuana-related businesses...more

Orrick, Herrington & Sutcliffe LLP

Investigations and Sanctions Regimes at Multilateral Development Banks: What You Need to Know

In the continuing COVID-19 pandemic, many companies face new COVID-19-related compliance risks, including increased anti-corruption scrutiny of pandemic relief efforts financed by multilateral development banks (MDBs or...more

Thomas Fox - Compliance Evangelist

Panic of 1907 and Compliance Expertise on the Board (UPDATED)

Ed Note-this week I am running a series on GameStop and compliance. To help understand how prior bubbles impacted economies, I a re-running a series I did a couple of years ago on the great financial disasters. Today, I...more

American Conference Institute (ACI)

[Virtual Event] Flagship Conference on Economic Sanctions Enforcement and Compliance - July 29th - 30th, 8:00 am - 5:00 pm EDT

The ACI’s 13th Advanced Flagship Conference on Economic Sanctions Enforcement and Compliance is going virtual and will be held on July 29-30, 2020.  From the comfort of your home office, virtually attend the industry’s...more

Thomas Fox - Compliance Evangelist

Panic of 1907 and Compliance Expertise on the Board

I recently listened to the Great Courses series of lectures, entitled Crashes and Crisis: Lessons form a History of Financial Disasters, hosted by Professor Connel Fullenkamp. It was so entertaining that this week I am...more

Thomas Fox - Compliance Evangelist

The Credit Suisse FCPA Enforcement Action: Part III – The Result and Going Forward

Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more

Thomas Fox - Compliance Evangelist

The Credit Suisse FCPA Enforcement Action: Part II – The (Very) Bad Facts

Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more

Thomas Fox - Compliance Evangelist

The Credit Suisse FCPA Enforcement Action: Part I – Background

Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more

The Volkov Law Group

Lessons Learned from Credit Suisse Corrupt Hiring Scheme and FCPA Settlement (Part II of II)

The Volkov Law Group on

Credit Suisse has joined the ranks of other banks and companies that have settled FCPA violations involving hiring of government officials’ relatives in exchange for business benefits, including JPMorgan Chase; BNY Mellon,...more

The Volkov Law Group

Rabobank Coughs Up $368 Million and Pleads Guilty to Conspiracy to Money Launder and Obstruct Investigation

The Volkov Law Group on

The Justice Department announced a guilty plea by a subsidiary of Rabobank, a Dutch global bank, to a conspiracy to violate money laundering laws and obstruct a regulatory investigation of Rabobank’s activities in California....more

Thomas Fox - Compliance Evangelist

Star Wars Week: Part III – Return of the Jedi – A good final result

While I am not sure how much celebrating HSBC might be doing this week, they should have pride in making it through the five-year DPA. The bank worked very hard to overcome its miss-steps and hopefully it will continue to do...more

Thomas Fox - Compliance Evangelist

Compliance Lessons for Executive Leadership from The Wells Fargo Investigation Report

Compliance lessons from truly one of the most damning reports of complete corporate failures around ethics and culture that has recently been seen....more

Thomas Fox - Compliance Evangelist

When Will Shareholders Force Boards to Do Compliance?

Today we honor one of the most iconic moments of World War II (WWII) and one of the most famous photographs of all time, that of the Marines raising the US flag on Mount Suribachi on the island of Iwo Jima. Marine...more

The Volkov Law Group

Aggressive Remediation: Embraer and JP Morgan

The Volkov Law Group on

There is no question that the Justice Department has raised compliance program expectations in a number of areas. Whatever you may think about the efficacy or fairness of the FCPA Pilot Program, the Justice Department has...more

The Volkov Law Group

Lessons Learned From FCPA Enforcement Against JP Morgan for Sons and Daughters Referral Program

The Volkov Law Group on

Last week, the Justice Department and the SEC finally brought to a close the Sons and Daughters or Princelings investigation. Pending investigations against four other companies still remain to be resolved....more

Thomas Fox - Compliance Evangelist

JPMorgan Sons and Daughters FCPA Enforcement Action, Part II

Today I will consider the superior result achieved by JPM in its FCPA resolution. Not only did it receive a 25% discount off the bottom of the US Sentencing Guidelines fine range but it received a NPA and not even a Deferred...more

Thomas Fox - Compliance Evangelist

Three Key Questions to Ask in Hiring of Family Members of Foreign Officials

One of the top academic commentators in the anti-corruption space is Matthew C. Stephenson, co-founder of the Global Anticorruption Blog. I was intrigued by Stephenson’s piece, entitled “Does an FCPA Violation Require a Quid...more

The Volkov Law Group

The Often Ignored Importance of Antitrust Compliance (Part I of II)

The Volkov Law Group on

If you ask any Chief Compliance Officer whether their compliance program includes antitrust laws, they will respond quickly and tell you – “Of course we do.” If you follow up you initial question and ask how do you ensure...more

Thomas Fox - Compliance Evangelist

Froome Ends Tour With Win; JP Morgan to End Sons and Daughters Case?

I begin today’s post with a tip of the (cycling) helmet to Englishman Chris Froome who yesterday won his third Tour de France championship. Froome overcame a great many obstacles, not the least of which was being involved a...more

K&L Gates LLP

DOJ Sharpens Focus on Corporate Compliance in Deciding Whether to Prosecute Companies

K&L Gates LLP on

One of the factors that the U.S. Department of Justice (DOJ) considers in deciding whether to bring charges against a corporation is the existence and effectiveness of the corporation’s pre-existing compliance program. On...more

K&L Gates LLP

Is Money Being Laundered Through Your Financial Institution Using Daily Fantasy Sports Sites?

K&L Gates LLP on

This alert addresses the explosion in popularity of daily fantasy sports (“DFS”) sites and the money-laundering potential that DFS sites may offer to criminals around the world. It then explains potential legal liability...more

Thomas Fox - Compliance Evangelist

Reflections on the Hitachi FCPA Enforcement Action

Earlier this week, the Securities and Exchange Commission (SEC) announced resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Hitachi Ltd (Hitachi). There were several interesting aspects to...more

MoFo Reenforcement

CFPB Brings Long-Anticipated First Redlining Enforcement Action – New Approach to Redlining Analysis is put into Action

MoFo Reenforcement on

On September 24, 2015, the CFPB and DOJ announced a joint action against Hudson City Savings Bank for allegedly discriminatory redlining practices from 2009 through 2013 in certain neighborhoods in New York, New Jersey,...more

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