A Third Party's Perspective on Third Party Risk
Cannabis Law Now Podcast: Cannabis Companies and the Corporate Transparency Act
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Episode 329 -- Bryn Sedlacek from Aravo on TPRM Holistic Risks and Unified Visibility
Episode 328 -- Sanctions Enforcement Risks and Redlines
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Examining FinCEN FAQs, Proposed Legislation and Other CTA Developments
Episode 320 -- NAVEX Hotline Report -- More Reports and Higher Substantiation
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
FCPA Compliance Report: DOJ on AI and Data/Intellectual Property Protection
Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm
Wiley's 10 Key Trade Developments: Evolution of Export Controls
Episode 311 -- Tom Fox on FCPA Enforcement: Self Disclosure and Recidivism
Webinar: Corporate Transparency Act
Wiley’s Top 10 Trade Developments: Heightened Sanctions and Export Control Enforcement
The EU Whistleblowing Directive
Episode 304 -- Nathalie Druckmann, VP at Certa, on Artificial Intelligence Third-Party Risk Management
JONES DAY TALKS®: Corporate Compliance in Asia: Managing Rapid Regulatory Change and Ambiguity
The EU Directive for Combatting Corruption
On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) published its final rule setting forth the circumstances under which beneficial ownership information reported to FinCEN pursuant to the Corporate...more
Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption risk. The key is to develop a mechanism to determine the appropriate level...more
In connection with the Biden Administration’s ongoing crackdown on corruption, tax havens, and illicit financing, on December 11, Treasury released a Fact Sheet on its “efforts to address the illicit finance and national...more
How much is an effective Anti-Money Laundering (“AML”) Compliance Program Worth? For Toronto-Dominion Bank (“TD”), the answer is at least $225 million––the amount that TD must now pay to First Horizon Bank, after backing...more
The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement. Last week, Lisa Monaco, DOJ’s...more
Federal prosecutors enjoy flipping through the United States Criminal Code, 18 U.S.C. §§ 1 et seq., to pick out tools to charge defendants. Over the last ten years, DOJ’s reliance on criminal charges in FCPA cases has...more
On June 3, 2021, the White House issued a memorandum formally establishing the fight against corruption as a core national security interest. The memorandum directed the development of a presidential strategy to, among other...more
The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals. ...more
On June 30, 2021, FinCEN announced the first set of government-wide AML/CFT Priorities, as required by the Anti-Money Laundering Act of 2020 ("AML Act"). Consistent with the National Strategy for Combating Terrorist and Other...more
There has been significant movement recently, by both the Biden Administration as well as Congress, to enhance the U.S. government’s ability to tackle corruption. This article provides a summary of those efforts and several...more
Congress needs to implement an effective ethics agenda. Important anti-corruption legislation has been sitting in various Senate and House committees awaiting action....more
The Biden Administration is taking over the reins of government with vigor and focus. The Department of Justice, the Treasury Department, the State Department and the Commerce Department are expected to coordinate closely in...more
On 24 December 2020, the UK and the EU reached a new Trade and Cooperation Agreement. The deal, which came into force on 1 January 2021, has important implications for white collar crime enforcement across Europe, and in...more
(i) a licensing regime for virtual asset trading platforms in Hong Kong, including anti-money laundering obligations; (ii) a two-tier registration regime for dealers in precious metals and stones; and...more
Anti-money laundering authorities are proposing a significant revision to the federal AML regulatory scheme with the aim of making it more effective while providing greater clarity to covered institutions. ...more
There are other U.S laws that intersect with the FCPA. A violation of the FCPA may also constitute a violation of the characteristics of another U.S. Law – in this case the Travel Act....more
Law Enforcement Has Been Using GTO Data - First of Two Posts on Evolving Issues Regarding Real Estate and Money Laundering - The U.S. Government Accountability Office (“GAO”) has issued a report on the status and...more
Compliance management has moved from being a nice to have, to an absolute need to have. For many organizations, it is part of business-as-usual (BAU). The scale and scope of compliance frameworks across the world have grown,...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
First Post in a Two-Post Series on Recent FATF Activity - Members presumably working from home, the Financial Action Task Force (“FATF”) was active last week, first issuing its 3rd Enhanced Follow-up Report & Technical...more
On 2/6/2020, the U.S. Department of the Treasury issued the 2020 National Strategy for Combating Terrorist and Other Illicit Financing (2020 Strategy). The purpose of the 2020 Strategy is to...more
El perfil de riesgo de la OFAC de una Institución Financiera se determina basado sus productos, servicios, clientes y ubicaciones geográficas. Se requiere que un programa de cumplimiento OFAC de una Institución Financiera...more
A Financial Institution’s OFAC risk profile is determined based on its products, services, customers and geographic locations. A Financial Institution’s OFAC compliance program is required to...more
On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more
Yesterday, the Department of Justice (DOJ) announced three charges against Jose Carlos Grubisich, the former Chief Executive Officer (CEO) of Braskem S.A. (Braskem), a publicly traded Brazilian petrochemical company, for his...more