Takeaways From Recent Claims Against Mark Zuckerberg and Facebook – Mitigating the Heightened Risk of Privacy Suits Against Individual Directors and Officers
Law School Toolbox Podcast Episode 280: Listen and Learn -- Piercing the Corporate Veil
Bar Exam Toolbox Podcast Episode 120: Listen and Learn -- Piercing the Corporate Veil
Compliance Perspectives: Compliance Officer Liability Risk
Lawyers on Tap: Tap Tips for Entity Formation and Taxation
FCPA Compliance Report-Episode 329, James Koukios
The Insider Trading Cartoon Series, Vol. XII -- The Innocent Intermediary
FCPA Compliance and Ethics Report-Episode 172-Scott Killingsworth on Personal Liability of CCOs
FCPA Compliance and Ethics Report Episode 129-Judge Rakoff, Judge Leon and Individual Prosecutions Under the FCPA
FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
What Are the Drastic Ramifications of the New York State Anti-Money Laundering Actions and Penalty Enforcement?
Before committing to a franchise business, consider...
On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its assessment of a civil monetary penalty totaling $450,000 against Michael LaFontaine, a former Chief Operational...more
On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more
The SEC continues to reiterate the role of broker-dealers as “gatekeepers to the securities markets” by focusing on firms’ anti-money laundering (“AML”) obligation. The import that the SEC, as well as FINRA, places on firms’...more
The election of President Trump contained some positive signs for Private Equity (PE) fund managers. These included potential lower corporate taxes, a ten-percent tax holiday for funds parked overseas, large infrastructure...more
Otherwise reputable Financial Institutions continue being sanctioned for regulatory non-compliance. Well known “household” names continue receiving fines for failing to establish and implement adequate Anti-Money Laundering...more
Yesterday I began an exploration of the potential individual liability of a Chief Compliance Officer (CCO) based upon the Financial Industry Regulatory Authority (FINRA) enforcement action against Raymond James Inc. and its...more
A horse is a horse, of course, of course, and no one can talk to a horse, of course. That is, of course, unless the horse is the famous Mister Ed. Those lines were the opening verse to the theme song of the TV...more
Update - This announcement comes just days after New York Governor Andrew Cuomo nominated Maria Vullo, another lawyer, to replace Benjamin Lawsky, who resigned as the Superintendent of the Department of Financial...more
Why it matters - The New York Department of Financial Services (DFS) may have launched its strongest offensive yet against observed shortcomings in the Bank Secrecy Act and anti-money laundering (BSA/AML) compliance...more
Earlier this month, Governor Andrew M. Cuomo of New York announced newly proposed anti-terrorism and anti-money laundering regulations that impose increased compliance requirements and more importantly, vastly expanded...more
Action Item: Benjamin Lawsky, the Superintendent of Financial Services for New York State, one of the country’s most aggressive regulators, is seeking to increase regulatory pressures on the financial services industry,...more
In February 2014, the Financial Industry Regulation Authority (FINRA), the self-regulatory body for the U.S. securities industry, suspended a former global anti-money laundering compliance officer at Brown Brothers Harriman &...more
Following months of rumors that the Financial Crimes Enforcement Network (FinCEN) is preparing to impose personal liability on officers, directors and employees for shortcomings in their financial institutions’ Bank Secrecy...more
Recent actions by the state of New York Department of Financial Services (NYDFS) regarding anti-money laundering (AML) fines and other sanctions imposed should cause financial institutions and their advisors to take notice,...more