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DOJ Announces “Pilot Program Regarding Compensation Incentives and Clawbacks” with Significant Ramifications for Corporations...

The Department of Justice Criminal Division announced a “Pilot Program Regarding Compensation Incentives and Clawbacks” (the “Program”) this week with broad implications for corporations and their individual executives...more

At Long Last, FinCEN Issues Beneficial Ownership Information Reporting Rule

At long last, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule establishing a beneficial ownership information reporting requirement for corporations and companies both large and small. In its...more

FinCEN Leader’s Remarks Focus on Securing Digital Identity

On September 7, 2022, Jimmy Kirby, the Acting Deputy Director of the Financial Crimes Enforcement Network (“FinCEN”), gave remarks during the 2022 Federal Identity Forum & Exposition (“FedID”) on the importance of securing...more

First FCPA Settlement of 2022 – Enforcement on the Horizon

On February 17, 2022, the Securities and Exchange Commission (SEC) announced the first Foreign Corrupt Practices Act (FCPA) settlement of the year. Seoul-based KT Corporation (KT Corp.), South Korea’s largest...more

FinCEN’s Proposed Foreign Affiliate SAR Sharing Program — Key Considerations

On January 25, 2022, the Financial Crimes Enforcement Network (“FinCEN”) solicited commentary regarding its proposed rule that would create a time-limited pilot program to expand the ability of financial institutions to share...more

Courts Adopt Different Approaches in Implementing the Due Process Protections Act

In a December 2020 article, we highlighted in this blog the amendment of Federal Rule of Criminal Procedure 5(f) in the new Due Process Protections Act (“DPPA” or “the Act”). The Act requires federal courts to enter a Brady...more

FinCEN Rule Ends AML Program Exemption for Banks that Lack a Federal Regulator

On September 15, 2020, the Financial Crimes Enforcement Network (“FinCEN”) published a Final Rule bringing banks that lack a federal functional regulator further under its purview. The rule subjects these institutions to...more

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