Due Diligence Dept. of Justice

News & Analysis as of

International AML Enforcement in 2017 Expected to Target Consumer-Due-Diligence Programs, Gaming Entities, Prepaid Cards, Digital...

Over the past two years, financial regulatory bodies in the United States and Europe have increasingly emphasized consumer due diligence (“CDD”) by financial institutions as a means to combat money laundering and terrorist...more

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

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

Volkov on the Evolving Standards for Compliance Programs

Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more

FCPA Enforcement Action Highlights Risks for the Financial Services Industry and Individual Executives

New York-based hedge fund Och-Ziff Capital Management Group (the “Hedge Fund”) agreed to pay approximately $412 million to resolve charges brought by the U.S. Securities and Exchange Commission (“SEC”) and Department of...more

Embraer FCPA Enforcement Action – Part IV

I conclude my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the resolution of...more

Embraer FCPA Enforcement Action – Part II

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

DOJ and SEC Raising the Stakes on Third Party Risk Management

If you review the last ten years of FCPA enforcement, the unmistakable pattern is rising expectations with regard to corporate compliance programs, particularly with regard to third party due diligence and risk management....more

Landmark SEC Decision Cites Compliance, Diligence in Decision Not to Prosecute FCPA Violations

In a remarkable affirmation of the value of robust compliance and due-diligence programs, the Securities and Exchange Commission last month announced that it would not prosecute a U.S. company for potential violations of the...more

Och-Ziff Failures in Due Diligence and Transaction Compliance (Part II)

The Och-Ziff enforcement action is replete with examples of failures in due diligence and transaction monitoring compliance. Och-Ziff’s bribery schemes were elaborate and intricate and involved complex transactions,...more

5 Key Takeaways from AB InBev SEC FCPA Settlement

The Justice Department and the SEC have been busy over the last 2 weeks in the FCPA arena. For those who have raised doubts about DOJ and the SEC’s continuing commitment to FCPA enforcement, you should forever hold your...more

No Longer a Mirage: FCPA Compliance and Cooperation Has Its Benefits

On September 12, 2016, the SEC announced that it had reached a settlement with Jun Ping Zhang (“Ping”), a former executive of a Chinese subsidiary of Harris Corporation (“Harris”), regarding alleged violations of the Foreign...more

The Ping FCPA Enforcement Action: Lessons for the Compliance Practitioner

The Securities and Exchange Commission (SEC) settled a Foreign Corrupt Practices Act (FCPA) enforcement action against an individual earlier this month when it announced the resolution of a matter involving Jun Ping Zhang,...more

Trust But Verify - Due Diligence with a Jaded Eye

Ronald Reagan’s mantra with respect to US-Soviet relations in the 1980s applies with equal force to today’s world of due diligence. (I know it shows my age that I can recall this statement). Not all due diligence cases...more

Looking at Culture with Compliance Program Assessments; Eric Feldman Explains [PODCAST].

Eric Feldman, Senior Vice President at Affiliated Monitors, Inc. discusses with me why third party assessments are essential for meeting the obligations outlined by the Federal Sentencing Guidelines. We also discuss the...more

Hallmark 7-Third-Party Due Diligence and Payments

There are five steps in the life cycle of third party management. - Business Justification and Business Sponsor; - Questionnaire to Third Party; - Due Diligence on Third Party; - Compliance...more

Hallmark 2 – Code of Conduct and Compliance Policies and Procedures

The cornerstone of a Foreign Corrupt Practices Act (FCPA) compliance program is its written protocols. This includes a Code of Conduct, policies and procedures. In the FCPA Guidance, the Department of Justice (DOJ) and...more

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

The Importance of Risk Ranking to Compliance

We all face a number of risks every day. Yet, we do not respond to each and every risk. We engage in risk-ranking our responses. Some are more risk than others and some are more catastrophic than others. So, we engage in risk...more

Third Party Risk Management: Balancing Due Diligence Screening and Monitoring

In response to aggressive FCPA enforcement and recurring problems with third parties, companies have spent substantial resources and time to design and implement comprehensive ethics and compliance programs. A key part of...more

The SEC, CCOs and Compliance Programs

Compliance programs, Chief Compliance Officers and liability have been the subject of a great deal of debate in recent months. Members of the Commission, for example, debated charging decisions regarding CCOs last year in...more

Are Your Company’s Legal, Due-Diligence, De-risking, or Compliance Obligations Impacted by the “Panama Papers”?

In an unprecedented event earlier this week, 11.5 million files from the Panamanian law firm Mossack Fonseca were allegedly leaked. Assuming they are genuine, as appears to be the case, these “Panama Papers” offer a...more

2016 M&A Report

Our 2016 M&A Report offers a detailed review of, and outlook for, the global M&A market. Other highlights include a comparison of deal terms in public and private acquisitions; updates on takeover defenses and public company...more

Olympus Settles FCPA Charges with DOJ

The Department of Justice resolved another FCPA investigation centered on payments made to health officials. Olympus Corporation of the Americas, a wholly owned subsidiary of Olympus Corporation, Tokyo, Japan, and Olympus...more

New Study Highlights Anti-Bribery & Corruption Gaps & Risks

Everyone reading this post should have conducted a corporate risk assessment (CRA) in the past couple years. If not, stop reading and go conduct one now. Seriously, how can you know if your compliance program resources,...more

Is Your HIPAA Compliance Program Ready for the FTC?

Everyone in healthcare knows that the next round of HIPAA audits is coming. Covered entities and business associates have long been advised to review and update their HIPAA security risk analyses, have business associate...more

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