The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
Exploring the AI and Crypto Intersection
The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
INTERPOL and Child Kidnapping Cases. What are INTERPOL’s Abilities and Limitations?
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The CFPB and State AGs Act Jointly Against Online Educational Company
Will the U.S. Have a GDPR? With Rachael Ormiston of Osano
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
The line between virtual and reality is getting thinner. Gamers pay gaming companies real currency for virtual in-game currency to buy skins, create the world they want to live in (virtually), or purchase loot that aid in...more
• Highlights of recent joint agency guidance on Third-Party Risk Management (3PRM) • How 3PRM considerations have increased in importance in BSA/AML compliance programs and enforcement actions • Lessons learned from...more
The Consumer Financial Protection Bureau (“CFPB”) continues focus its forces on the payment processing space. In June 2023, we published an article foretelling the next regulatory frontier: nonbank payment systems. In July...more
On June 27, 2023, the CFPB filed an administrative consent order against a payment processor headquartered in Elkhorn, Nebraska. The order alleges that on a single date in 2021, the processor erroneously initiated about 1.4...more
On January 12, the U.S. District Court for the Eastern District of Virginia ruled that a credit union (defendant) is responsible for $558,000 in compensatory damages for processing a payment order that was allegedly induced...more
Risk management personnel who underwrite e-commerce merchants should have some basic understanding of the types of online merchant marketing and sales practices that are deceptive and misleading....more
Most of the Federal Trade Commission’s (FTC) law enforcement actions involving payment processors have exclusively focused on allegations that processors did not do sufficient due diligence before onboarding questionable...more
On May 24, the FTC finalized an order against an electronic payment processor and its owners for allegedly opening credit card processing accounts for fake companies on behalf of a scam company previously sued by the FTC....more
Yesterday, the Federal Trade Commission (FTC) moved to dismiss its long-running enforcement action against Electronic Payment Solutions (EPS) pending in the District of Arizona after the Commission voted 4-0 to approve a...more
In recent years, payment processors and other financial intermediaries have faced heightened scrutiny from regulatory agencies, including the Federal Trade Commission, for their relationships with companies engaged in...more
A few weeks ago, we wrote an article discussing two enforcement actions by the Federal Trade Commission in the Central and Southern Districts of California that highlighted the risks to payment processors and financial...more
We frequently post about negative option marketing in this blog, but our focus has been the FTC’s enforcement actions against businesses that utilize this marketing strategy. We haven’t written as much about a different risk:...more
The laws and rules governing automatic renewal programs continue to change on a regular basis. Over the past year, the Federal Trade Commission has announced a number of settlements and lawsuits enforcing the federal Restore...more
On January 18, after approximately fourteen months of settlement negotiations, the CFPB announced that it secured a settlement agreement with BrightSpeed Solutions, Inc., a third-party payment processor that had ceased...more
On December 16, the Federal Trade Commission (FTC) voted 4-0 to issue an Advance Notice of Proposed Rulemaking (ANPRM) to commence a rulemaking targeting rising business and government impersonation fraud. Critically, the...more
On November 8, 2021 the Federal Trade Commission (FTC) announced that it entered into a stipulated order with a payment processor, resolving allegations that the payment processor violated Section 5 of the Federal Trade...more
The Treasury Department’s Office of Foreign Asset Control continues to focus enforcement activities on digital currency companies. This focus is likely to increase given recent comments by Janet Yellen, the head of the...more
On February 10, 2021, the Federal Trade Commission (FTC) announced settlements with two payment processing companies and two individuals, resolving claims concerning an alleged credit card laundering scheme perpetrated in...more
On December 10, 2020, the Federal Trade Commission (Commission) announced that it reached a settlement with a payment processor and its former CEO for alleged violations of the Federal Trade Commission Act (FTCA). ...more
On May 19, 2020, the Federal Trade Commission announced that it had reached a $40.2 million settlement with a payment processing company and one of its executives after the company allegedly failed to monitor and heed...more
This survey summarizes several recent developments affecting bank deposits and payment systems. These include payments-related consent orders and enforcement actions by the Consumer Financial Protection Bureau (“CFPB”) and...more
AML Scandals Seem to Inevitably Spawn Investor Lawsuits - As we recently blogged, Westpac, Australia’s second-largest retail bank, has been embroiled in a scandal arising from approximately 23 million alleged breaches of...more
Bank Accused of Being Asleep at the AML-CTF Switch - On November 20, 2019, AUSTRAC, Australia’s anti money-laundering (“AML”) and counter-terrorism financing (“CTF”) regulator, initiated an action in the Federal Court of...more
Payment processor/facilitator Allied Wallet, its CEO, and two other corporate officers, recently agreed to settle Federal Trade Commission (FTC) charges that they assisted or knowingly processed fraudulent transactions for...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued guidance on May 9, 2019, underscoring the application of the Bank Secrecy Act (BSA) and its implementing regulations relating to money...more