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
Episode 295 -- Deep Dive into the Albemarle DOJ and SEC FCPA Settlements
August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more
Senator Bob Menendez (D-NJ), former Chair of the U.S. Senate Committee on Foreign Relations, has been found guilty in his federal corruption case for, among other things, bribery, obstruction of justice, and acting as a...more
Since the Corporate Transparency Act took effect on January 1, 2024, scammers have seized the opportunity to send notices to owners of recently formed companies offering “filing services.” In response to these scams, FinCEN...more
On March 1, 2024, Judge Liles C. Burke of the Northern District of Alabama, Northeastern Division, ruled in U.S. v. Yellen that the Corporate Transparency Act (the “Act”) is unconstitutional. The federal district court found...more
On March 1, 2024, the United States District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (CTA) exceeds the constitutional limits on Congress’s legislative power and is therefore...more
Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more
On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more
If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm. However, that is not the corporate reality. Even after several companies are the...more
This is a basic primer describing the Corporate Transparency Act (“CTA“) which was enacted into federal law on January 1, 2021 as part of the Anti-Money Laundering Act of 2020 and became effective January 1, 2024. The...more
Adding to federal prosecutors’ tool kit in fighting global corruption, on December 14, 2023, Congress passed with bipartisan support, the Foreign Extortion Prevention Act (FEPA). As part of the National Defense Authorization...more
As everyone knows, I tend to repeat myself — DOJ does as well. Over the past year, DOJ has warned global companies — over and over — about the coming criminal enforcement storm against companies for sanctions and export...more
CTA Denial #3: “My industry’s lobbyists would never allow such a law to get passed.” Lobbyists had staved off attempts to implement the CTA, and its predecessor bills, for decades....more
Beginning January 1, 2024, certain privately held companies, known as “reporting companies,” will be required to file a Beneficial Ownership Information (BOI) Report to identify, and provide personal information about, their...more
The purpose of the Corporate Transparency Act isto “better enable critical nationalsecurity, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other illicit activity” by...more
The Corporate Transparency Act (the “CTA”), which takes effect on January 1, 2024, will require many companies to report certain beneficial ownership information to the Financial Crimes Enforcement Network (“FinCEN”), a...more
I recently had the opportunity to visit with Dr. Ian Oxnevad, Director of Geopolitical Risk Intelligence at Infortal Worldwide. Global Risk Review, a podcast series that Infortal Worldwide sponsors was the reason for this...more
This alert provides a summary of new reporting requirements created by the Corporate Transparency Act (the “CTA”) and associated implementing rules. The CTA is a federal law that requires broad categories of legal entities...more
The Justice Department has made it clear that it intends to prioritize criminal prosecution of national security cases to prevent hostile nation-states from illegally acquiring sensitive U.S technology. To this end, DOJ...more
To restate the obvious – DOJ has prioritized prosecution of national security crimes. For the business world, every company touches the international economy. Even a domestic company might sell products or services outside...more
Key Points - On March 2, 2023, DOJ announced that its NSD would hire more than 25 new prosecutors to investigate and prosecute sanctions evasion, export controls violations and similar economic crimes. Consistent with...more
On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 in the National Defense Authorization Act for Fiscal Year 2021. Congress passed the CTA to...more
The Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued final regulations to implement the reporting requirements under the federal Corporate Transparency Act (CTA). The CTA aims to further...more
Since his election, President Joe Biden has loudly reaffirmed U.S. ambitions in the fight against global corruption, domestically and abroad. Thus, in June 2021 the “Biden memorandum” declared the fight against...more
Key Takeaways - A judge has issued an opinion in a first-of-its-kind criminal sanctions case involving the use of virtual currency to evade U.S. economic sanctions. The opinion reinforces the Treasury Department’s position...more
Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions. The dye is cast, so here we go. ...more