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Shell Corporations White Collar Crimes

The Volkov Law Group

Gunvor’s Bribery Schemes — Third-Parties, Shell Companies and Evasion of Controls (Part II of III)

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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

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 2 – The Bribery Schemes

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

American Conference Institute (ACI)

Sanctions Compliance Measures to Mitigate Russia Trade Sanctions Evasion Tactics

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

A&O Shearman

Pandora Papers Fallout: Proposed US Legislation Targets “Enablers” of Money Laundering

A&O Shearman on

The release of the Pandora Papers, a leak of approximately 12 million documents, exposed how foreign leaders and private actors use tax havens to conceal their wealth, with the United States a destination of choice. For...more

Polsinelli

The Corporate Transparency Act and Pandora’s Papers

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With the recent release of the “Pandora Papers,” renewed attention is focused on corporate ownership transparency. Earlier this year, Congress passed the Corporate Transparency Act (“CTA”). The CTA was enacted to combat the...more

The Volkov Law Group

DOJ Charges Two Austrian Bankers with Money Laundering as Part of Massive Odebrecht Bribery Scheme

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The Department of Justice is starting to launch its FCPA enforcement profile after a brief lull in DOJ’s transition to a new administration.  This enforcement lull occurred in the transition to the prior administration in...more

Society of Corporate Compliance and Ethics...

Expectations remain high for Biden administration's fight against corruption

CEP Magazine (March 2021) - With a new administration in the White House, all those in favor of greater transparency are expecting greater strides to be made in the anti-corruption effort. In spring 2020, then-US...more

Cohen & Gresser LLP

Pulling Back the Curtain: Congress Establishes a Beneficial Ownership Registry for U.S. and Foreign Businesses

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On January 1, 2021, Congress overrode President Trump’s veto, passing into law the annual National Defense Authorization Act for Fiscal Year 2021 (“NDAA”). ...more

The Volkov Law Group

J&F Investmentos FCPA Settlement: Lessons Learned (Part IV of V)

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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

The Volkov Law Group

DOJ Charges Two Sons of Former Panama President Martinelli with Participation in Odebrecht Bribery Scheme in Panama

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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

Ballard Spahr LLP

United States “Beats” Switzerland as a Perceived Global Haven for Money Laundering and Tax Evasion

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The Cayman Islands Receive “Top Honors.”  But, Global Financial Transparency is Reportedly Improving in General - The United States has overtaken Switzerland as a financial secrecy haven, according to the latest rankings –...more

Ballard Spahr LLP

Corporate Transparency Act of 2019 Broadens Beneficial Ownership Reporting

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In early March, the House Financial Services Committee released three proposed bills to codify many of the suggested reforms discussed during ongoing conversation among financial agencies, law enforcement, financial...more

Ballard Spahr LLP

Update: First Defendant Pleads and Agrees to Cooperate in $1.2 Billion Alleged Venezuelan Laundering Scheme

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As we have blogged, the United States Attorney’s Office for the Southern District of Florida is pursuing charges against eight individuals for allegedly conspiring to launder $1.2 billion embezzled from a Venezuelan...more

Thomas Fox - Compliance Evangelist

Farewell to Volkoff and to Shell Companies

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

Thomas Fox - Compliance Evangelist

Chaucer, the Canterbury Tales and Shell Companies

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

Bricker Graydon LLP

Personal liability trend continues: Health care CEO gets jail time for fraud scheme

Bricker Graydon LLP on

The Department of Justice (DOJ) recently announced that the CEO of Indiana-based American Senior Communities (ASC) was sentenced to over 9 years in federal prison for his involvement in a “massive fraud, kickback, and money...more

Ballard Spahr LLP

FinCEN Issues Advisory on Human Rights Abuses Enabled by Corrupt PEPs and Their Financial Facilitators

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On June 12, 2018, FinCEN issued an “Advisory on Human Rights Abuses Enabled by Corrupt Senior Foreign Political Figures and their Financial Facilitators” to highlight the connection between corrupt senior foreign political...more

The Volkov Law Group

DOJ Settles Follow-On FCPA Case: Transport Logistics Pays $2 Million Penalty

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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

Ballard Spahr LLP

“Panama Papers” Law Firm Announces Its Closure Due to Fallout from Massive Data Breach

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The beleaguered law firm at the center of the international Panama Papers scandal – Mossack Fonseca – has announced that it is closing its doors. It offered no apologies....more

Robinson+Cole Manufacturing Law Blog

Settlement with Swedish Telecom Giant Falls Just Short of First $1 Billion FCPA Resolution

In September, the U.S. government announced a nearly $1 billion FCPA (Foreign Corrupt Practices Act) settlement with the Swedish telecommunications company Telia. The total monetary payment in this global resolution makes it...more

Thomas Fox - Compliance Evangelist

The Telia FCPA Resolution, Part I

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

The Volkov Law Group

Important Polling Results from BVD Webinar on Beneficial Ownership

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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

The Volkov Law Group

AML Enforcement and Compliance Trends

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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

Thomas Fox - Compliance Evangelist

How the Yellow Submarine Informs Due Diligence Lessons From 1MDB

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

The Volkov Law Group

Customer Due Diligence in the Post-Panama Papers Era

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Sometimes it takes a scandal to advance a policy or law enforcement cause. The Panama Papers scandal has given new life to financial regulators around the world who seek to impose customer due diligence requirements on banks...more

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