FCPA Compliance and Ethics Report-Episode 42, Interview with Patrick Taylor of Oversight Systems on Transaction Monitoring
FCPA Compliance and Ethics Report-Episode 35-Transaction Monitoring
Transaction Monitoring Under the FCPA
On July 22, 2019, the United States Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced that they had resolved allegations of Foreign Corrupt Practice Act (“FCPA”) violations against...more
Initially, it would not seem that much was new or different about the Microsoft FCPA enforcement action but through this exploration, I think some clear lessons have emerge. The first is around internal controls. Here there...more
Banca d'Italia, con il Provvedimento del 26 marzo 2019, ha emanato le nuove "Disposizioni in materia di organizzazione, procedure e controlli interni volti a prevenire l'utilizzo degli intermediari a fini di riciclaggio e di...more
First Post in a Two-Part Series - How do financial institutions get in trouble with their regulators? Recent AML enforcement actions suggest that the following two failures are at the heart of most of these actions: (1)...more
The Och-Ziff settlement has now set the stage for the Justice Department and the SEC to focus its enforcement eye on the private equity and hedge fund industry. The Och-Ziff action was initiated in response to the SEC’s...more
On June 30, 2016, the New York Department of Financial Services (DFS) adopted a new anti-terrorism and anti-money laundering (AML) regulation (Final Rule) that builds on federal anti-money laundering requirements to address...more