The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
Wicked Coin: The "Fat Leonard" Scandal
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
RICO Vicarious Liability — RICO Report Podcast
Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm
RICO Damages — RICO Report Podcast
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 305 -- Deep Dive into SAP FCPA Settlement
AGG Talks: Antitrust and White-Collar Crime Roundup - Developments in the Trump Indictments and Recent Supreme Court Issues
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
AGG Talks: Antitrust and White-Collar Crime Roundup - Examining the Latest Updates in the Pending Criminal and Civil Litigation Against Trump
The EU Directive for Combatting Corruption
On May 30, 2024, following passage by the European Parliament in late April, the European Council officially adopted a set of rules that modernizes and harmonizes money laundering and terrorist financing (“AML/CFT”)...more
In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more
The Foreign Corrupt Practices Act (FCPA) (15 U.S.C. § 78dd-1 et seq.) is a federal anti-bribery law that makes it unlawful for certain people to pay foreign government officials in order to conduct business abroad. While it...more
In-person is back! Join us in Amsterdam for the 2023 European Compliance & Ethics Institute! Strengthen your compliance and ethics program by attending our 11th annual European Compliance and Ethics Institute, 20-22 March...more
A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more
On June 30, 2021, FinCEN announced the first set of government-wide AML/CFT Priorities, as required by the Anti-Money Laundering Act of 2020 ("AML Act"). Consistent with the National Strategy for Combating Terrorist and Other...more
On June 3, 2021, President Biden issued the first National Security Study Memorandum of his presidency, in which he declared fighting corruption “a core United States national security interest.” The Memorandum sets out the...more
The Anti-Money Laundering Act of 2020 (AML Act) serves as the starting point for financial institutions and companies looking to understand what to expect from the Biden administration with respect to anti-money...more
In today’s world, companies in various industries are increasingly running into issues that have national security implications. Research universities and other academic institutions can face issues involving national...more
Although courts have reined in the application of the Foreign Corrupt Practices Act (FCPA) anti-bribery provisions in the past two years, the US Department of Justice (DOJ) shows no sign of scaling back its global...more
The Financial Action Task Force (“FATF”) just released an important report entitled Money Laundering and the Illegal Wildlife Trade (the “Report”). The lengthy and detailed Report makes clear that the IWT is pernicious...more
Impact of COVID-19 on Cross-Border Disputes - Cross-border disputes in the year 2020 are likely to be significantly impacted by the current outbreak of COVID-19, and disputes involving Latin America are no exception. The...more
Beneficial ownership is a topic which presents significant challenges to compliance officers charged with untangling a web of ownership interests that span numerous international jurisdictions and ownership structures. ...more
I. Background - Sweden’s financial supervisory authority (“SFSA”) recently fined Swedbank AB a record 4 billion Swedish kronor (approximately $386 million) for deficiencies in its anti-money laundering (“AML”) processes...more
Second Post in a Two-Post Series on Recent FATF Activity - As we just blogged, the Financial Action Task Force (“FATF”) issued a statement from its President on COVID-19 and measures to combat illicit financing during the...more
On March 31st the Financial Action Task Force (FATF)—the global AML/CFT standard-setting body and watchdog—announced that it has upgraded the United States for technical compliance with FATF Recommendation 10 following...more
The U.S. Department of the Treasury 2020 Strategy (National Strategy for Combating Terrorist and Other Illicit Financing released on February 6, 2020) describes ongoing significant AML/CFT threats. ...more
First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more
The Financial Action Task Force (FATF) on February 21, 2020, reintroduced its call for countries to impose countermeasures to protect themselves from illicit finance threats emanating from Iran. The call for countermeasures...more
On 2/6/2020, the U.S. Department of the Treasury issued the 2020 National Strategy for Combating Terrorist and Other Illicit Financing (2020 Strategy). The purpose of the 2020 Strategy is to...more
Goldman Sachs is reportedly in negotiations with federal prosecutors to resolve claims about its role in the Malaysian 1MDB scandal for upwards of $2 billion. A settlement—which “could include a guilty plea from Goldman’s...more
I thought Frosty was a good analogy to consider the disgraced Goldman Sachs Group Inc.’s former partner Tim Leissner, as he is certainly back again. Yesterday, I begin a two-part blog post series on Leissner’s settlement with...more
Bank Accused of Being Asleep at the AML-CTF Switch - On November 20, 2019, AUSTRAC, Australia’s anti money-laundering (“AML”) and counter-terrorism financing (“CTF”) regulator, initiated an action in the Federal Court of...more
On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more
As reported by Byron Tau and Aruna Viswanatha in the Wall Street Journal (WSJ), “Jho Low, the businessman-turned-fugitive accused of masterminding a multibillion-dollar fraud involving Malaysia’s sovereign-wealth fund, agreed...more