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Third-Party Relationships Enforcement Actions

WilmerHale

Interagency Issuances on Bank-Fintech Partnerships Highlights Risks, Opportunities, Importance of Industry Participant Engagement

WilmerHale on

The recent bank regulatory Joint Statement and request for information (RFI) on third-party deposit relationships and bank-fintech partnerships emphasize afresh regulators’ long-standing concern with financial institutions’...more

Goodwin

2023 Year in Review: Fintech

Goodwin on

Welcome to the Fintech chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - The CFPB is expected to finalize rulemaking authorizing supervision of payment application...more

The Volkov Law Group

Lessons Learned from the Albemarle FCPA Enforcement Action: Mind Your Third Parties (Part III of III)

The Volkov Law Group on

The Albemarle FCPA enforcement action was announced at a good time.  This year has been a slow year for DOJ’s FCPA enforcement program, although there are several months before the end of the year. The SEC, on the other hand,...more

The Volkov Law Group

Albemarle’s Reliance on Third-Parties to Execute Bribery Schemes (Part II of III)

The Volkov Law Group on

Albemarle’s bribery schemes look and sound like text-book examples of third-party agents being paid high commissions as a way to funnel bribery payments to foreign officials at state-owned oil refineries.  However, as usual,...more

Ballard Spahr LLP

Guilty Pleas Highlight Illicit Funneling of Chinese Cash to Casinos

Ballard Spahr LLP on

Government Suggests that Unusual Pleas are Just the Tip of an Iceberg - Chinese law generally prohibits its citizens from converting more than $50,000 in Chinese yuan into foreign currency in a year.  On Monday, two men...more

The Volkov Law Group

2019 OFAC Sanctions Enforcement Review (Part I of II)

The Volkov Law Group on

While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement.  OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions.  That is quite an increase...more

Robins Kaplan LLP

Financial Daily Dose 1.15.2020 | Top Story: Dating Apps Face Scrutiny for Likely Data Privacy Violations

Robins Kaplan LLP on

Popular app-based dating services—from Tinder to OkCupid to Grindr—are the subject of unwanted scrutiny this week after a report by the Norwegian Consumer Council that they’re “spreading user information like dating choices...more

Foodman CPAs & Advisors

Instituciones Financieras y el FCPA

La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios.  Exige que las empresas cuyos valores se...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It requires companies whose securities are listed in the US to maintain books and...more

Thomas Fox - Compliance Evangelist

Bribery Schemes from 2019 FCPA Enforcement Actions

In today’s blog post, I want to look at some of the more unusual bribery schemes from Foreign Corrupt Practices Act (FCPA) enforcement actions in 2019. Some of these schemes were not unusual but they were accomplished with...more

Skadden, Arps, Slate, Meagher & Flom LLP

Ericsson Agrees To Pay Over USD $1 Billion To Settle FCPA Charges

On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 5: Lessons Learned for the Compliance Professional

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

The Volkov Law Group

Ericsson’s Pervasive Bribery Conduct: The Toxic Mix of Senior Executive Involvement and Third Party Corruption (Part II of II)

The Volkov Law Group on

Ericsson’s FCPA settlement is in the books (not the books and records).  But it casts a significant shadow across the FCPA landscape.  A pervasive and systemic culture of bribery is defined to reflect senior executive...more

Thomas Fox - Compliance Evangelist

The Ahsani’s Information – Final Thoughts

This week I have been considering the guilty pleas of the former Unaoil Chief Executive Officer (CEO), Cyrus Ahsani, and former Chief Operations Officer (COO), Saman Ahsani, as was laid out in their Information. Most...more

The Volkov Law Group

Walmart’s Recipe for Corruption Disaster: Rapid International Growth without a Compliance Program Foundation (Part II of III)

The Volkov Law Group on

The Walmart case, from a big picture standpoint, represents a serious warning to all global companies committed to rapid international growth.  In the absence of a significant and sustained commitment to compliance, rapid...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 2 – The Bribery Schemes

The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced last week. This massive case came in with multiple documents, a long list of instances of bribery and corruption, a...more

The Volkov Law Group

United Technologies Pays $13.9 Million to Settle FCPA Charges (Part I of II)

The Volkov Law Group on

The SEC’s FCPA Unit had a good week last week – they announced a second FCPA settlement along with the Sanofi case. The latest to fall was United Technologies that agreed to pay $13.9 million for bribes paid by its elevator...more

Ballard Spahr LLP

FATF Report: Professional Money Laundering and Related Threats

Ballard Spahr LLP on

The Financial Action Task Force (“FATF”) recently released a special report on professional money launderers (“PMLs”) who provide money laundering expertise and services to their crime-committing clients. ...more

Snell & Wilmer

New Fed Policy Eliminates Ability of Settlement Options to Include Payments to Non-Party NGOs

Snell & Wilmer on

On June 7, 2017, United States Attorney General Jeff Sessions issued a memorandum to all Department of Justice (DOJ) components and 94 United States Attorney’s Offices prohibiting them from entering into any agreement on...more

Holland & Knight LLP

Justice Department Reveals How It Evaluates Corporate Compliance Programs

Holland & Knight LLP on

The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

K2 Integrity

The DOJ Expects “Third-Party Management” from Compliance Programs

K2 Integrity on

2016 was a banner year for global anti-corruption enforcement: the U.S. government set records in terms of both the number of FCPA actions brought and the total dollar amount of related fines. Meanwhile, governments from...more

The Volkov Law Group

Third Party Risk Management: Balancing Due Diligence Screening and Monitoring

The Volkov Law Group on

In response to aggressive FCPA enforcement and recurring problems with third parties, companies have spent substantial resources and time to design and implement comprehensive ethics and compliance programs. A key part of...more

Foley Hoag LLP - Global Business and Human...

The California Transparency in Supply Chains Act: New Guidance and Increased Enforcement Efforts

The State of California has recently stepped up enforcement of the California Transparency in Supply Chains Act, which went into effect on January 1, 2012. The California Department of Justice has also issued new guidance on...more

Proskauer - Privacy & Cybersecurity

BBB Warns Advertisers and Web Publishers to Take Responsibility for Behavioral Advertising Disclosures

The Better Business Bureau (“BBB”) and the Direct Marketing Association (“DMA”) are in charge of enforcing the ad industry’s Self Regulatory Principles for Online Behavioral Advertising (“OBA Principles”), which regulate the...more

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