On 20 March 2025, enforcement authorities in the UK, France and Switzerland announced the creation of the International Anti-Corruption Prosecutorial Taskforce. The taskforce is comprised of:
- The UK’s Serious Fraud...more
On 12 February 2025, the UK Supreme Court handed down its decision in El-Khouri v Government of the United States of America (El-Khouri), declining to extradite Joseph El-Khouri to the US. The ruling marks a pivotal moment in...more
3/3/2025
/ AML/CFT ,
Anti-Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Enforcement Actions ,
Extradition ,
Financial Conduct Authority (FCA) ,
Fraud ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Litigation ,
UK ,
White Collar Crimes
On February 10, 2025, President Donald Trump signed an executive order directing the U.S. attorney general, Pam Bondi, to pause Foreign Corrupt Practices Act (FCPA) actions for 180 days until she issues revised FCPA...more
2/13/2025
/ Anti-Corruption ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
The UK government introduced a major overhaul of its framework for addressing financial crime — and brought into force numerous significant changes — when the Economic Crime and Corporate Transparency Act 2023 (the Act)...more
9/12/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Corporate Crimes ,
Corporate Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Enforcement Actions ,
EU ,
Failure to Prevent ,
Financial Crimes ,
Fraud ,
Strict Liability ,
UK ,
White Collar Crimes
On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more
8/6/2024
/ Anti-Corruption ,
CFTC ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FinCEN ,
Government Agencies ,
Pilot Programs ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
On March 26, 2024, the French Anti-Corruption Agency (AFA) published a guide on how to engage in corporate sponsorship and charitable donation activities while appropriately mitigating corruption risks (the Guide)...more
5/13/2024
/ AFA ,
Anti-Corruption ,
Charitable Donations ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
EU ,
France ,
Internal Investigations ,
New Guidance ,
Self-Reporting ,
Sponsorship Agreements ,
UK ,
White Collar Crimes
On April 15, 2024, the Department of Justice’s (DOJ’s) Criminal Division unveiled a new Pilot Program on Voluntary Self-Disclosures for Individuals that offers non-prosecution agreements (NPAs) to individuals who voluntarily...more
4/24/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Federal Pilot Programs ,
Financial Institutions ,
Financial Services Industry ,
Non-Prosecution Agreements ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
On December 22, 2023, President Biden signed into law the Foreign Extortion Prevention Act (FEPA) as part of the fiscal year 2024 National Defense Authorization Act. FEPA criminalizes demand-side bribery by foreign officials...more
1/9/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Bribery ,
Corruption ,
Extortion ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Hobbs Act ,
NDAA ,
White Collar Crimes
DOJ Increases Resources To Investigate and Prosecute Sanctions Evasion and Export Control Violations -
On March 2, 2023, during a keynote speech at the American Bar Association’s annual White Collar Crime National...more
3/17/2023
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Corporate Entities ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
UK ,
Voluntary Disclosure
On January 16, 2023, France’s financial prosecutor, the “Parquet National Financier” (PNF), issued updated guidance (the Guidelines) regarding its approach to offering, negotiating and entering into French deferred...more
2/6/2023
/ Anti-Corruption ,
Anti-Money Laundering ,
Attorney-Client Privilege ,
CJIP ,
Compensation ,
Corporate Crimes ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement ,
France ,
Guidance Update ,
Public Statements ,
Reporting Requirements ,
UK ,
White Collar Crimes
On January 17, 2023, the U.S. Department of Justice (DOJ) announced revisions to the Criminal Division’s Corporate Enforcement Policy. The revisions follow Deputy Attorney General (DAG) Lisa Monaco’s September 2022...more
1/24/2023
/ Anti-Corruption ,
Anti-Money Laundering ,
Commodities ,
Corporate Governance ,
Corporate Misconduct ,
Cross-Border ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
False Claims Act (FCA) ,
Investigations ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
White Collar Crimes
On December 6, 2021, the White House released "United States Strategy on Countering Corruption" (the Strategy Paper), which outlines the Biden administration's focus on fighting corruption as a core national security interest...more
On 23 October 2020, the UK Serious Fraud Office (SFO) updated its Operational Handbook, publishing a new chapter on deferred prosecution agreements (DPAs) (the Chapter). This note summarizes key points from the Chapter and...more
On June 1, 2020, the Criminal Division of the U.S. Department of Justice (DOJ) released updates to its Evaluation of Corporate Compliance Programs guidance (Guidance), last revised in April 2019. ...more
Addressing the Evolving Risks -
Warren Buffett said that “only when the tide goes out do you discover who’s been swimming naked.” Buffett was not talking about compliance programs in a time of crisis, but his wisdom applies...more
5/2/2020
/ Anti-Corruption ,
Anti-Money Laundering ,
BSA/AML ,
Compliance ,
Coronavirus/COVID-19 ,
Corporate Misconduct ,
Cybersecurity ,
Disclosure Requirements ,
Economic Sanctions ,
Enforcement Actions ,
FFIEC ,
Financial Distress ,
Financial Fraud ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Market Manipulation ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Public Health Emergency ,
Publicly-Traded Companies ,
Risk Assessment ,
Risk Mitigation ,
Sanction Violations ,
Securities and Exchange Commission (SEC)
While enforcement agencies have yet to indicate that they intend to put their pens down in response to COVID-19, there is anecdotal evidence that some agencies have slowed their investigations as remote working impacts matter...more
3/31/2020
/ Anti-Corruption ,
Anti-Money Laundering ,
CFTC ,
Compliance ,
Coronavirus/COVID-19 ,
Debt Market ,
Disruptive Trading Practices ,
Economic Sanctions ,
Enforcement Actions ,
Equity Markets ,
Financial Conduct Authority (FCA) ,
France ,
Market Abuse ,
Risk Management ,
Social Distancing ,
Tax Evasion ,
UK Bribery Act ,
White Collar Crimes