Money Laundering

News & Analysis as of

White-collar crimes: companies could soon be held accountable

Proposals for a new criminal finance bill will, if implemented, hold company boards criminally responsible for offences such as money-laundering and false accounting committed by their employees. This is a move that is being...more

Spoofing, Sports and the Panama Papers: BakerHostetler Offers Mid-Year Review of Cross-Border Government Investigations and...

Halfway through 2016, the international community has seen a staggering variety of cross-border investigations and enforcement actions. Brexit, the release of the Panama Papers, allegations of widespread sports doping and the...more

Virtual Currency May Not Be Money but Dismissal Is Real

Is bitcoin money? Not according to a Florida judge who threw out criminal charges against a defendant accused of money laundering and acting as an unlicensed money services business in violation of state law. What...more

Government Charges Sixteen In $175 Million Pharmacy Fraud

On September 1, 2016, the United States Attorney’s Office for the Southern District of Florida filed a five-count information, variously charging sixteen individuals, including three physicians, in connection with a scheme to...more

The Panama Papers - What the Fallout Means for U.S. Companies and Professionals [Video]

White Collar Defense/Internal Investigations Partner Peter D. Hardy discusses the financial implications of the Panama Papers leak on U.S. companies and professionals, the growing perception of the United States as a tax...more

Good-Bye to Wyatt Earp and More on 1MDB

Wyatt Earp died this week. Not the original Wyatt Earp who died in 1929 but the Wyatt Earp of my lifetime, who was actor Hugh O’Brian. O’Brien portrayed Earp in the long running television series Wyatt Earp which ran in the...more

Customer Due Diligence in the Post-Panama Papers Era

Sometimes it takes a scandal to advance a policy or law enforcement cause. The Panama Papers scandal has given new life to financial regulators around the world who seek to impose customer due diligence requirements on banks...more

FinCEN Proposes AML Program Requirement for Banks without a Federal Functional Regulator

FinCEN has proposed extending its anti-money laundering (AML) program requirement for banks to banks that are not subject to regulation by a federal functional regulator, including state chartered limited purpose trust...more

FinCEN Proposal Looks to Extend AML Requirements to Non-Federally Regulated Banks

On April 25, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, proposed a rule that would require all banks, regardless of whether they are subject to regulation by a...more

Being a Returned Fugitive from Justice May Not Be the Worst Thing

But don’t flee justice! This is not legal advice to you, but I really don’t mean to recommend avoiding problems with federal prosecutors by going to other countries where it’s hard for those prosecutors to catch up with you....more

Florida Court: Bitcoin Isn’t “Money”, and Selling It Isn’t “Transmission”

A Florida criminal court has exonerated a defendant charged with violating state money transmission and money laundering laws. In Florida v. Espinoza, the State of Florida charged Michell Abner Espinoza with one count...more

Will the Panama Papers Lead to Criminal Charges Against U.S. Taxpayers?

The International Consortium of Investigative Journalists (ICIJ), collaborating with German newspaper Süddeutsche Zeitung, in spring 2016 began leaking approximately 11 million internal documents obtained without permission...more

Train Your Board and C-Suite Now – The Under-Education of Corporate Leadership

The next time we read about a train wreck of corporate malfeasance – be it in the anti-corruption, money laundering, financial reporting or any other space you can think of – please do not shrug your shoulders and shake your...more

FinCEN Expands Targeting of High-End Cash Real Estate Transactions

FinCEN has announced a major expansion and extension of its geographic targeting orders (GTOs) aimed at high-end cash buyers of real estate. This action reflects FinCEN’s continued efforts to prevent money laundering through...more

FinCEN Tightens the Screws on Money Launderers with Additional Scrutiny of High-Value Residential Real Estate Transactions

Choice real estate markets such as New York, Miami, Los Angeles, San Francisco, San Diego, and San Antonio may offer enticing amenities like buzzing nightlife or sunny beaches, but thanks to the Financial Crimes Enforcement...more

DOJ and SEC Collect $22 Million from LAN Airlines for Conduct in Resolving Labor Dispute

Last week, the Justice Department and the SEC announced parallel FCPA settlements totaling $22 million in fines, penalties and disgorgement against LAN Airlines, a Chile-based airline, for conduct in resolving a labor dispute...more

Financial Services Weekly News - July 2016 #4

Editor's Note - What Exactly Is Bitcoin? In a case featuring a sting operation beginning with meetings in a coffee shop, ice cream store and hotel lobby and ending with the sale of bitcoins to an undercover Miami Beach...more

Florida Judge Rules Bitcoin is not Money

On July 25, a Florida Circuit Court judge dismissed state criminal charges against a defendant who attempted to sell bitcoins for $30,000 in cash on the ground that bitcoins are not money. Defendant Michell Abner Espinoza...more

Red Flags Squelch Corrupt PDVSA Deal

As the Petrobras corruption scandal seems to be going strong, we turn our attention to what may be the most corrupt of all the national energy companies, the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA)....more

New confiscation recommendations: a price worth paying?

On 15 July 2016, the Home Affairs Committee published a report on the Proceeds of Crime. The report identifies a number of systemic problems with the current confiscation order system and makes several recommendations...more

New out-of-court settlement in Belgium for bribery, fraud and money laundering offences

A new law has introduced an out-of-court criminal dispute resolution procedure which is available to, inter alia, a legal entity accused of bribery, fraud or money laundering. Provisions relating to another alternative to...more

Blog: Home Affairs Select Committee concludes UK needs to do more to address money laundering and corruption

The House of Commons Home Affairs Committee has published a report entitled ‘Proceeds of Crime’ in which it is highly critical of the efforts being made and systems in place in the UK to prevent money laundering and to...more

Your daily dose of financial news - The Brief – 7.20.16

We’ve heard about VW’s $15 billion settlement to resolve US claims by owners and regulators, but a spate of recent state AG-led actions shows that the fallout from the emissions cheating scandal is far from over. NY, MA, and...more

Enforcement Week I: Troubling Questions Raised in HSBC Prosecution

We had an interesting week of anti-corruption enforcement actions last week, both in the US and the UK. We have now had four Foreign Corrupt Practices Act (FCPA) enforcement actions since the announcement of the Depart Of...more

New Frontier for Bank Secrecy Act Prosecutions: Trade-Based Money Laundering

Since the September 11, 2001, terrorist attacks, U.S. law enforcement and financial regulatory agencies have focused on disrupting the use of the financial system by terrorist groups, criminal organizations and tax evaders to...more

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