On September 15, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its first “Gap Rule” enforcement action in a Consent Order with Bancrédito International Bank and Trust...more
We conclude our exploration of one of the most public cases of corporate moral bankruptcy where Lafarge SA and its Syria unit Lafarge Cement Syria, or LCS, each pled guilty to a count of conspiring to provide material support...more
Recently, three of Australia's four largest banks have self-reported breaches of anti-money laundering and counter-terrorism financing laws. Commonwealth Bank of Australia in 2018 admitted fault and agreed to pay a civil...more
Last week, a colleague asked me what I thought the Trump administration might hold for Foreign Corrupt Practices Act (FCPA) enforcement specifically and for the greater compliance discipline in general. I have been exploring...more
Donald Trump has gone on the record as saying the Foreign Corrupt Practices Act (FCPA) is a “horrible law and it should be changed” and that it puts US businesses at a “huge disadvantage.” This statement was made in the...more