News & Analysis as of

Due Diligence and The Holy Grail — Red Flags

Compliance professionals love to bandy about the term “red flag.” It is a term with infinite meanings depending on the context. A red flag in a money-laundering context is different than a red flag in a corruption context....more

Anti-Bribery and Corruption Compliance Practices

Compliance Week published its 2014 Anti-Bribery and Corruption Benchmarking Report, a survey of over 180 executives involved in ethics and FCPA compliance and internal audit. The Survey focused on risk, dealing with third...more

Regulators Increasingly Pursue Individual Liability for Money-Laundering Violations

The Financial Crimes Enforcement Network (FinCEN), an arm of the U.S. Department of Treasury, recently fined a Miami-based money services business (MSB) and its owner $10,000 for failing to implement proper anti-money...more

Casino AML Compliance Update: Las Vegas Sands Corp. Places Macau Casino Junkets Under Increased Scrutiny.

On April 4, 2014, Bloomberg reported that the Las Vegas Sands Corp. (“Sands”) has increased its scrutiny of casino junket operators in Macau. The decision comes as casinos seek to meet the increased demands of federal...more

Behind Royal Allegations: Leveraging the Fraud Triangle to Positively Impact Your Anti-Corruption Training

It seems that the Spanish royal family can’t do anything right these days. Recall that the initial tarnish on the family came from legal, albeit unseemly occurrences (i.e. rumors of the King’s extra-marital affairs, the...more

This Week In Securities Litigation (The week ending January 10, 2014)

The insider trading trial of former SAC Capital official Matthew Martoma opened this week in Manhattan with jury selection. The SEC announced the resignation of George Canellos, Co-director of the Division of Enforcement....more

The International Comparative Legal Guide to: Business Crime 2014 - An Overview of Business Crime in Latin America

Latin America’s “Culture of Corruption” - The notion that there is a “culture of corruption” in Latin America has led some writers to note that decades of unstable economies and turbulent politics in the region have...more

Money Laundering on the Front Burner

With the bulk of the banking industry’s credit problems resolved or at least more manageable than in the recent past, the regulators appear to be on a new warpath. Over the last year, they have sent strong signals to the...more

AML Enforcement And Virtual Currencies

It is difficult for regulators and law enforcement to keep up with creative new ways in which criminals choose to store and trade money. This is especially true in the Internet-age where anonymity and ease of communications...more

New York Announces Agreement To Resolve Alleged International Sanctions Violations

On June 20, New York announced a consent order with the New York branch of a foreign bank to resolve charges that the bank — over a five year period that ended more than five years ago — violated Bank Secrecy Act, Anti-Money...more

Federal Reserve Board Requires AML Enhancements Prior To Bank Merger

On June 18, the Federal Reserve Board announced the execution of a written agreement with a bank and its bank and non-bank subsidiaries to resolve alleged shortcomings in the institutions’ BSA/AML compliance programs....more

Recent FCPA Enforcement Actions Show Increased Scrutiny on Financial Services Sector

Last week, the U.S. Department of Justice (DOJ) announced the indictment of a managing partner of U.S. broker-dealer Direct Access Partners (DAP) for violations of the Foreign Corrupt Practices Act (FCPA), the Travel Act, and...more

‘You Scratch My Back’ Leads To A Fine And Penalty

The above lyrics are the closing stanza to the song “Ghost Riders in the Sky”. I thought about the advice for the cowboy to change his ways to save his soul from Hell when I read in both the Financial Times (FT) and the Wall...more

How To Assess Suspicious Financial Activity

The banking world is littered with institutions that have paid astronomical fines for their failures around anti-money laundering (AML) legislation....more

AML Transaction Monitoring

Compliance programs depend on accurate and timely information. AML compliance centers on sifting through thousands of transactions and matching them against risk profiles. ...more

Marine Transportation and Anti-Money Laundering

My recent article on the marine transportation industry and the Foreign Corrupt Practices Act (FCPA) generated some discussion ranging wider than simply the port agent issue regarding interaction with foreign government...more

A Compilation of Enforcement and Non-Enforcement Actions - January 31, 2013

In This Issue: Non-Enforcement Matters - FINRA Announces Regulatory and Examination Priorities for 2013 - SEC Previous Hedge Fund Enforcement Trends for 2013 Enforcement Matters - Another...more

The HSBC AML Settlement - Lessons Learned for the AML Compliance Practitioner

I recently wrote about banks behaving badly. Currently, Exhibit A in that list is HSBC. In December, 2012, the UK banking giant HSBC agreed to pay a fine of $1.92 billion for its transgressions involving money laundering....more

Banks Take It On The Chin

The end of the year was very tough for global banks. For months significant enforcement actions were expected in the ongoing LIBOR manipulation probe and anti-money laundering and sanctions violations probes....more

Outsourcing of AML Compliance: How Far Can A Financial Institution Go?

Several banking giants, such as HSBC and Standard Chartered, are currently being investigated by US regulators for alleged failings in anti-money laundering (AML) compliance. What is the reason for these large banks’...more

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