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Compliance Department of Justice (DOJ) Shell Corporations

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 -
Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 2 – The Bribery Schemes

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more

Bracewell LLP

KYC in a Digital World, How New Sanctions and AML Expectations Have Upped the Stakes and What you Need to Do About it

Bracewell LLP on

“Know your customer” is a bed rock principle of anti-money laundering and sanctions compliance programs, but it’s not always easy, particularly as more sophisticated and aggressive players have taken the field in recent...more

The Volkov Law Group

J&F Investmentos FCPA Settlement: Lessons Learned (Part IV of V)

The Volkov Law Group on

J&F Investmentos (“J&F”) FCPA settlement presents a number of important lessons learned.  While the bribery scheme was brazen and involved a large amount of money, the techniques and warning signs must have been fairly...more

The Volkov Law Group

DOJ Charges Two Sons of Former Panama President Martinelli with Participation in Odebrecht Bribery Scheme in Panama

The Volkov Law Group on

DOJ announced the arrest of two individuals, Luis Martinelli Linares and Ricardo Martinelli Linares, who are the sons of the former President of Panama, Ricardo Martinelli) for their role in funneling $28 million in bribes to...more

The Volkov Law Group

DOJ Settles Follow-On FCPA Case: Transport Logistics Pays $2 Million Penalty

The Volkov Law Group on

Last week, the Justice Department announced its first FCPA enforcement action in 2018 – a follow-on settlement from prior FCPA enforcement actions centering on a bribery scheme involving a Russian government official from a...more

Thomas Fox - Compliance Evangelist

The Telia FCPA Resolution, Part I

While the resolution of the Telia Company (Telia) Foreign Corrupt Practices Act (FCPA) matter has long been awaited, the results announced yesterday by the Department of Justice (DOJ) and Securities and Exchange Commission...more

The Volkov Law Group

AML Enforcement and Compliance Trends

The Volkov Law Group on

Law enforcement focus on anti-money laundering appears to be increasing. While the last ten years has seen a marked increase in AML regulatory obligations, the new administration is likely to return to some of the more...more

Thomas Fox - Compliance Evangelist

How the Yellow Submarine Informs Due Diligence Lessons From 1MDB

Enrichment is the theme for today’s post as it is personal and illegal enrichment which seems to be the continuing message from the 1MDB scandal involving the disgraced Malaysian sovereign wealth fund. In an article in the...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Expands Scope of “All Cash” GTOs

Continuing its efforts to deter the use of real estate as a vehicle to launder proceeds of criminal activity, the Financial Crimes Enforcement Network (FinCEN) recently announced its plan to extend the reach and time frame of...more

Thomas Fox - Compliance Evangelist

Gulliver’s Travels, Truth or Fiction?

There was once a man named Gulliver who traveled widely and wrote a book about his adventures called Gulliver’s Tales. During his first voyage, Gulliver is washed ashore after a shipwreck and finds himself a prisoner of a...more

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