Compliance officers in financial services have long struggled with aspects of Customer Due Diligence, better known as the CDD Rule. This fall, compliance professionals are scratching their heads to know exactly how much due...more
One cannot really say enough about risk assessments in the context of anti-corruption programs. Since at least 1999 the DOJ has said that risk assessments that measure the likelihood and severity of possible Foreign Corrupt...more
The Fourth European Union Anti-Money Laundering Directive (Fourth AML Directive), approved by the European Parliament on May 20, 2015, went into effect on June 25, 2015, repealing the 2005 Third AML Directive. Given the...more