Patent Infringement: Successful Litigation Stays the "Course"
Podcast - Chamber of Commerce v. Internal Revenue Service
As we’ve noted in earlier bulletins, in an effort to gain visibility into ownership and control of business entities operating in the United States, the federal Corporate Transparency Act (“Act”) went into effect January 1,...more
I’m not talking about your organization. I’m talking about that company in your vendor master files. A recent report from Moody’s found some downright silly attributes about shell companies. One that jumped out at me was the...more
Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more
Gunvor’s bribery scheme is not very surprising nor ingenious. After all, a number of energy trading companies have been prosecuted for bribery over the years, including Glencore, Vitol, Freepoint. Numerous individuals have...more
We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more
The Corporate Transparency Act (CTA), which became effective on January 1, 2024, was enacted to combat the use of shell companies by those seeking to evade anti-money laundering laws and economic sanctions. ...more
The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more
The Corporate Transparency Act became law in the United States on January 1, 2021 and required compliance beginning on January 1, 2024. For more information about the background of the statute, please read our prior articles...more
We previously noted in our March 31, 2022 alert that the U.S. Securities and Exchange Commission (SEC or Commission) held an open meeting on March 30, 2022 to consider proposed rules and amendments regarding special purpose...more
The Staff of the Division of Corporation Finance at the Securities and Exchange Commission (SEC) has recently begun issuing comment letters in the life sciences reverse merger (RM) context that involve a broadened...more
The Corporate Transparency Act (CTA) was enacted in 2021 and became effective on Jan. 1, 2024. The CTA was passed with the aim of enhancing transparency in corporate ownership, so as to combat the proliferation of anonymous...more
Thursday, September 29, 2022, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Final Rule regarding the beneficial ownership reporting requirements under the Corporate Transparency Act...more
“Know your customer” is a bed rock principle of anti-money laundering and sanctions compliance programs, but it’s not always easy, particularly as more sophisticated and aggressive players have taken the field in recent...more
J&F Investmentos (“J&F”) FCPA settlement presents a number of important lessons learned. While the bribery scheme was brazen and involved a large amount of money, the techniques and warning signs must have been fairly...more
DOJ announced the arrest of two individuals, Luis Martinelli Linares and Ricardo Martinelli Linares, who are the sons of the former President of Panama, Ricardo Martinelli) for their role in funneling $28 million in bribes to...more
The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...more
It seems somehow fitting this week in the midst of the Astros inexorable march back to the World Series that we honor the only baseball player across the globe simply known as “The Emperor”. He was, of course, Masaichi Kaneda...more
Weirdly, Volkoff informs today’s post and not simply because of President Trump’s fawning over all things Russian. We wrap-up the blog series about the continuing dangers of shell companies, as articulated by Ryan C. Hubbs,...more
According to Samuel Rubenfeld, reporting in the Wall Street Journal (WSJ) Risk & Compliance Journal, “Treasury Secretary Steven Mnuchin told lawmakers that he wants to make corporate ownership information available to law...more
Last week, the Justice Department announced its first FCPA enforcement action in 2018 – a follow-on settlement from prior FCPA enforcement actions centering on a bribery scheme involving a Russian government official from a...more
While the resolution of the Telia Company (Telia) Foreign Corrupt Practices Act (FCPA) matter has long been awaited, the results announced yesterday by the Department of Justice (DOJ) and Securities and Exchange Commission...more
On July 5, 2017, Bureau Van Dijk, a sponsor of my blog, conducted a webinar on the importance of beneficial ownership information to corporate compliance functions....more
Anti-money laundering professionals are in for a rude awakening. Know Your Customer or KYC requirements are currently kicking up a notch, and will be even more dramatic when the new FinCEN beneficial ownership regulations...more
Law enforcement focus on anti-money laundering appears to be increasing. While the last ten years has seen a marked increase in AML regulatory obligations, the new administration is likely to return to some of the more...more
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