News & Analysis as of

Foreign Corrupt Practices Act (FCPA) BSA/AML Department of Justice (DOJ)

Troutman Pepper Locke

Key Considerations After DOJ Announces Shifting Enforcement Priorities

Troutman Pepper Locke on

On February 5, U.S. Attorney General (AG) Pam Bondi issued 14 memoranda to Department of Justice (DOJ) employees framing the DOJ's current policies and enforcement priorities. These shifting enforcement priorities are aligned...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

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

Ballard Spahr LLP

White House Releases Sweeping U.S. Strategy on Countering Corruption

Ballard Spahr LLP on

Last week, the Biden Administration unveiled a sweeping “whole-of-government approach” to combating corruption. Identifying corruption as a “cancer within the body of societies—a disease that eats at the public trust and the...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

Fenwick & West LLP

DOJ Cryptocurrency Enforcement Framework Highlights Risk for Those Engaged in Virtual Asset and Cryptocurrency Activity

Fenwick & West LLP on

In case it was not already clear, the U.S. Department of Justice recently confirmed that ensuring the use of cryptocurrency “is safe, and does not imperil our public safety or our national security, is vitally important to...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

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

Ballard Spahr LLP

The EU’s Efforts to Combat Money Laundering, the Financing of Terrorism and Corruption Seem to Overlook a Very American Approach:...

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The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...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

The Volkov Law Group

The Risk of a Cooperating Witness Left Out in the Cold

The Volkov Law Group on

Last week, the Justice Department reported a guilty plea in the VW emissions scandal prosecution. By this one announcement, DOJ signaled that it is planning to build a bigger case against VW. Ironically, the Justice...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

K&L Gates LLP

Heard at the 2016 SIFMA Conference

K&L Gates LLP on

Recently, attorneys from K&L Gates’ Government Enforcement practice group attended the Securities Industry and Financial Markets Association’s (“SIFMA”) Compliance and Legal Society Annual Seminar. We wanted to share with you...more

Thomas Fox - Compliance Evangelist

Why Should Americans Care About the FIFA Indictments? Part I – Only the US Government Could Do It

A colleague recently posed that question to me. I thought it was an interesting one and although at first blush the response to me might appear self-evident, the fact that it was posed means that my view may not be universal....more

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