News & Analysis as of

Shell Corporations Due Diligence

American Conference Institute (ACI)

Sanctions Compliance Measures to Mitigate Russia Trade Sanctions Evasion Tactics

The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more

Neal, Gerber & Eisenberg LLP

Client Alert: Beware of Fake CTA Reporting Requests

The Corporate Transparency Act (CTA), a law intended to enable the Financial Crimes Enforcement Network (FinCEN) to detect shell companies and protect the U.S. financial system from abuse by money launderers, drug...more

A&O Shearman

Pandora Papers Fallout: Proposed US Legislation Targets “Enablers” of Money Laundering

A&O Shearman on

The release of the Pandora Papers, a leak of approximately 12 million documents, exposed how foreign leaders and private actors use tax havens to conceal their wealth, with the United States a destination of choice. For...more

Snell & Wilmer

New Year, New Laws – Congress Passes Major Anti-Money Laundering Act

Snell & Wilmer on

On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, an omnibus bill that includes the Anti-Money Laundering Act of 2020 (“AMLA”). The AMLA bans the use of anonymous shell companies...more

Thomas Fox - Compliance Evangelist

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

Pillsbury Winthrop Shaw Pittman LLP

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

Thomas Fox - Compliance Evangelist

The Panama Papers and Shell Games, Part I

One of the more prescient authors I know is Ryan C. Hubbs, a senior manager of fraud investigation and dispute services at Ernst & Young LLP (EY), who, in 2014, wrote an article for Fraud Magazine entitled “Shell Games”. In...more

K&L Gates LLP

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

K&L Gates LLP on

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

Snell & Wilmer

Money Laundering Crackdown in Real Estate Sector?

Snell & Wilmer on

The Director of the Financial Crimes Enforcement Network (also known as FinCEN) recently gave a speech in San Francisco regarding the agency’s investigative priorities. Director Jennifer Shasky Calvery’s comments drew media...more

Thomas Fox - Compliance Evangelist

British PM Leads The Fight Against Shell Corporations

One of the critical areas in due diligence for foreign business partners is determining who are the true owners of an entity....more

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