Money Laundering Compliance

News & Analysis as of

T’Was the Week After Christmas: General Cable and Mexico Aviation FCPA Prosecutions

You know this has been a big year in FCPA enforcement when DOJ and the SEC announce two FCPA settlements during the usually sleepy week between Christmas and New Years. And what a year it has been – more to follow in my...more

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

Key Takeaways: Government Enforcement Investigations – Trends and Perspectives from the UK, US and China

On September 20, 2016, Skadden presented a seminar titled “Government Enforcement Investigations – Trends and Perspectives from the UK, US and China” in London. The UK Financial Conduct Authority (FCA) Director of Enforcement...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

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

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

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

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

Top Ten International Anti-Corruption Developments for January 2016

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month, with links to primary...more

[Webinar] White Collar Crimes in Indo-U.S. context: Do’s and Don’ts - Meritas Capability Webinar - Feb. 3rd, 10:00am EST

While emerging markets represent untapped growth potential and investment opportunities, there is often a sharp contrast between global best practices and compliance requirements and accepted business practices prevalent in...more

Is Money Being Laundered Through Your Financial Institution Using Daily Fantasy Sports Sites?

This alert addresses the explosion in popularity of daily fantasy sports (“DFS”) sites and the money-laundering potential that DFS sites may offer to criminals around the world. It then explains potential legal liability...more

FATF updates guidance

FATF has published the outcomes of its plenary meeting in Paris. The main issues dealt with by this plenary were: - combating terrorist financing, which remains the top priority for FATF...more

Investment Management Update - October 2015

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

Foreign Corrupt Practices Act 2015 Update

Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more

FinCEN's Recently Proposed AML Rule: A Road Map for SEC-Registered Investment Advisers

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposed Rule) on September 1, 2015 that would impose anti-money laundering (AML) requirements for investment...more

Advisers Charged with Cleansing Dirty Money from Industry

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more

You’re the Man—Government Targets Individuals in FCPA Cases

The government has increasingly focused its FCPA enforcement firepower on individuals. On August 31, a Russian official living in Maryland pled guilty to conspiracy to commit money laundering in connection with arranging $2...more

ECJ publishes MLD3 due diligence interpretation opinion

ECJ has published an opinion in the case of Safe Interenvíos S.A. v. Liberbank S.A. and Others. Three banks had closed accounts a payment institution held with them, on the basis of money laundering concerns. The request for...more

FinCEN Action Against Casino for Weak AML Compliance Efforts Should Not Be Ignored by Others—Especially Digital Currency Companies

Why it matters - FinCEN's $8 million civil money penalty imposed on Caesars Palace for "willful and repeated" violations of the BSA sends a signal that failure to collect and use appropriately identifying information...more

AML Update: The Rumors Are True – FinCEN Proposes Regulations That Will Require SEC Registered Investment Advisers to Adopt an AML...

On September 1, 2015, the Financial Crimes Enforcement Network (“FinCEN”) published in the Federal Register long-rumored proposed regulations that will require Securities and Exchange Commission (“SEC”)-registered investment...more

Securities Litigation and Enforcement Newsletter

A CD or not a CD, That is the Question… That the Auditors Should Have Answered - A headline-grabbing SEC enforcement action last week against BDO USA and several of its national partners may lead audit firms to insist on...more

Top Ten International Anti-Corruption Developments for August 2015

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month, with links to primary...more

Treasury launches “red tape” consultation

Treasury has launched a review designed to improve the effectiveness of rules designed to prevent money laundering and terrorist financing (AML/CTF). The review forms part of Treasury’s aim to save businesses money by cutting...more

FinCEN Proposes to Apply AML/BSA Requirements to Investment Advisers

FinCEN is an active law enforcement agency. They have taken on more responsibility over the last five years for AML enforcement, and they show no signs of letting up. FinCEN’s proposal to expand beneficial ownership...more

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