News & Analysis as of

Bribery BSA/AML

Womble Bond Dickinson

Navigating the Labyrinth: Artificial Intelligence in the Battle Against Trade-Based Money Laundering

Womble Bond Dickinson on

In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more

Thomas Fox - Compliance Evangelist

Levels of Due Diligence

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

Orrick - Finance 20/20

FinCEN Urges Financial Institutions to Focus on Detecting Proceeds of Foreign Public Corruption

Orrick - Finance 20/20 on

The Financial Crimes Enforcement Network (“FinCEN”) recently issued an advisory urging financial institutions (including certain cryptocurrency businesses) to implement controls to help detect proceeds of foreign public...more

The Volkov Law Group

Prosecutors Embrace Criminal AML Charges in Corruption Cases

The Volkov Law Group on

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

Manatt, Phelps & Phillips, LLP

The Government’s New Strategy To Counter Corruption: What You Need To Know

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 Volkov Law Group

The United States Strategy on Countering Corruption: Digging into the Anti-Corruption Initiatives (Part III of III)

The Volkov Law Group on

The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals.  ...more

Cadwalader, Wickersham & Taft LLP

DOJ Casts the FCPA Spotlight on Brazil-Related Enforcement

On May 25, 2021, the U.S. Department of Justice (“DOJ”) unsealed an indictment charging two Austrian citizens, Peter Weinzierl (“Weinzierl”) and Alexander Waldstein (“Waldstein”), for their roles in a scheme to launder...more

The Volkov Law Group

Biden Administration Ramping Up Anti-Corruption Effort

The Volkov Law Group on

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

Robins Kaplan LLP

Financial Daily Dose 1.19.2021 | Top Story: Fiat Chrysler and PSA Group Finalize Merger to Form Auto Behemoth Stellantis NV

Robins Kaplan LLP on

Fiat Chrysler and France’s PSA Group completed their mega-auto-merger first agreed-to in late 2019, “creating Stellantis NV, a global auto-making giant that executives say will have the heft needed to compete in the...more

Ballard Spahr LLP

CFTC and DOJ Charge BitMEX and Executives With Illegally Trading in Digital Assets and Ignoring BSA/AML Requirements

Ballard Spahr LLP on

Incorporating in the Seychelles but Allegedly Operating in the U.S. Spells Trouble for Company and its Founders - The Bitcoin Mercantile Exchange, or BitMEX, is a large and well-known online trading platform dealing in...more

Foodman CPAs & Advisors

Violating the FCPA may Trigger other U.S. Laws such as the Travel Act

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

Foodman CPAs & Advisors

Instituciones Financieras y el FCPA

La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios.  Exige que las empresas cuyos valores se...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It requires companies whose securities are listed in the US to maintain books and...more

Thomas Fox - Compliance Evangelist

Ex-Braskem CEO Indicted on FCPA, AML and Books and Records Charges

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

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - January 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including DOJ guidance on the use of corporate monitors in criminal...more

Cadwalader, Wickersham & Taft LLP

White Collar Crime Law Enforcement in a Trump Justice Department - 8 Predictions

After a conventional presidential campaign, determining the policy priorities and direction of the incoming administration with respect to the Justice Department’s white collar law enforcement responsibilities can be a...more

Thomas Fox - Compliance Evangelist

Good-Bye to Arnold Palmer and Revolutionizing Compliance

The golfing world and the world of beverages lost one of their giants earlier this week. I, of course, refer to golfing and beverage legend Arnold Palmer. The legend around the beverage is that at dinner one evening Palmer...more

Thomas Fox - Compliance Evangelist

Compliance Program Lessons from a Recidivist

Recidivist behavior is something that the US government is forced to face in Foreign Corrupt Practices Act (FCPA) enforcement from time-to-time. When a company agrees to a Deferred Prosecution Agreement (DPA) or...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

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