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Enrichment is the theme for today’s post as it is personal and illegal enrichment which seems to be the continuing message from the 1MDB scandal involving the disgraced Malaysian sovereign wealth fund. In an article in the...more
The Och-Ziff enforcement action is replete with examples of failures in due diligence and transaction monitoring compliance. Och-Ziff’s bribery schemes were elaborate and intricate and involved complex transactions,...more
FCPA enforcement efforts are not so hard to follow and predict – the government likes to provide advance warnings as an effective means of deterrence. Justice Department and SEC officials will often tell the public their...more