Trade-based money laundering (TBML) describes a set of techniques through which drug traffickers, terrorists and other criminals use the veneer of trade to move illicit funds across borders while disguising the origin and...more
10/16/2023
/ Anti-Money Laundering ,
BSA/AML ,
Criminal Conspiracy ,
Criminal Prosecution ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Drug Trafficking ,
Enforcement Actions ,
FinCEN ,
Indictments ,
International Trade ,
Law Enforcement ,
Money Laundering ,
Popular ,
re Grand Jury ,
Supply Chain ,
Terrorism Funding ,
Trade-Based Money Laundering
Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors.
In a speech at Georgetown University Law Center on...more
2/7/2023
/ Bribery ,
Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Corruption ,
Declination ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Foreign Corrupt Practices Act (FCPA) ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
Updated DOJ policies will continue to focus on individual accountability and corporate recidivism, while aiming to provide additional incentives for voluntary self-reporting, foster greater transparency on use of monitors,...more
9/28/2022
/ Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Corporate Officers ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Personal Liability ,
Voluntary Disclosure
今回の米国司法省の政策変更において、司法省は個人の責任に一層の重点を置き、また企業の過去の違法行為に対しては包括的な評価を行い、さらに企業との司法解決に対してはより厳格な対応をすることとなる -
2021年10月28日、米国司法省 （United States Department of Justice、以下「DOJ」）...more
11/30/2021
/ Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Misconduct ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement ,
Government Investigations ,
Internal Revenue Code (IRC) ,
Japan ,
Multinationals ,
White Collar Crimes
The changes include more focus on individual accountability, more holistic evaluation of prior corporate misconduct, and stricter corporate resolutions.
On October 28, 2021, US Deputy Attorney General Lisa Monaco gave the...more
11/1/2021
/ Attorney General ,
Biden Administration ,
Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Culture ,
Corporate Misconduct ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement ,
Internal Investigations ,
Non-Prosecution Agreements ,
Policy Statement ,
White Collar Crimes
The DOJ’s National Cryptocurrency Enforcement Team and Treasury’s OFAC are setting their sights on cryptocurrency use in cybercrimes.
The US Department of Justice (DOJ) is sharpening its focus on combatting...more
10/29/2021
/ Blockchain ,
Compliance ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Enforcement Authority ,
Financial Crimes ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
SDN List ,
U.S. Treasury ,
Virtual Currency
US Department of Justice’s sprawling report reveals regulatory enforcement priorities for cryptocurrencies and highlights multi-agency cooperation.
On October 8, 2020, the US Attorney General’s Cyber-Digital Task Force of...more
10/20/2020
/ AML/CFT ,
Cryptoassets ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement ,
Financial Regulatory Agencies ,
Information Reports ,
Popular ,
Securities and Exchange Commission (SEC) ,
Strategic Enforcement Plan ,
Suspicious Activity Reports (SARs)
Ruling holds that the government cannot use conspiracy and accomplice liability theories to reach foreign nationals that lack US ties.
Key Points:
..Non-resident foreign nationals who are not otherwise subject to direct...more
The revised FCPA Corporate Enforcement Policy signals DOJ’s emphasis on corporate voluntary self-disclosure, rewarding cooperating companies with a presumption in favor of declination and reductions in penalties.
...more
Key Points:
- DOJ is reviewing and reevaluating numerous corporate enforcement policies, including the “Yates Memo,” the FCPA Pilot Program, and policies on corporate monitors.
- Policies will be codified in official...more
DOJ may revise policies on using investigatory tools to procure information about the media, with significant legal and business implications.
Key Points:
..The review marks DOJ’s second significant evaluation of media...more
The announcement reflects the increasing cooperation between US and UK anti-corruption prosecutors, a trend with significant implications on both sides of the Atlantic.
Key Points:
..Two-year secondment marks the first...more
The extension of the program — which emphasizes voluntary self-disclosure of FCPA violations, raises considerations for corporate entities and individual executives.
The Department of Justice (DOJ) recently announced...more
A serious shift of focus to individual accountability may impact traditional corporate defense and settlement tactics.
On September 9, 2015, the Department of Justice (DOJ) issued a set of guidelines that formally revise...more
In a brief — and swiftly decided — per curiam decision issued June 4, 2015, the US Court of Appeals for the Second Circuit affirmed the wire fraud and wire fraud conspiracy convictions of three former UBS Financial Services,...more