News & Analysis as of

White Collar Crimes

Leadership Lessons from Abraham Lincoln

by Thomas Fox on

The leadership lessons from the race to the South Pole renewed my interest in leadership for the compliance practitioner. In a New York Times (NYT) article, entitled “Lincoln’s School of Management”, Nancy F. Koehn, a...more

Richard Bistrong: Who’s gaming your compliance program?

Instead of completing compliance training modules on their own, three Credit Suisse bankers had their administrative assistants do the work for them. Originally published on the FCPA Blog, - February 21,...more

Under Advisement: SEC Scrutinizes Wealth Management Industry

Recent events have made it clear that there is an increased regulatory focus on the conduct of investment professionals in the wealth-management industry. ...more

Top Ten International Anti-Corruption Developments for February 2018

by Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

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

by Michael Volkov on

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

First FCPA Action of 2018: Elbit Imaging

by Michael Volkov on

No one needs to be reminded about the importance of anti-corruption compliance. For global companies, anti-corruption risks are amongst the top 3 risks identified by corporate leaders....more

Canada's 2018 budget heralds introduction of deferred prosecution agreements for corporate wrongdoing

by Dentons on

For those interested in white collar enforcement trends in Canada, the 2018 Budget (the “Budget”), contained some important news. Specifically, as part of a broader commitment to “strengthening [Canada’s] approach to...more

Brainstorming for Compliance

by Thomas Fox on

Brainstorming can be a useful and indeed powerful tool in the business world. In my corporate career I participated in several large brainstorming sessions to help develop or focus on new product or service initiatives....more

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

by Ballard Spahr LLP on

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

An Introduction To The UK's Unexplained Wealth Orders

Law enforcement authorities in the U.K. have obtained a new instrument in their fight against crime. Starting Jan. 31, 2018, U.K. enforcement authorities can apply for court orders against individuals suspected of being...more

Tribute to Hawking: Black Holes Everywhere

by Thomas Fox on

Holmes was one of the most famous women to come out of Silicon Valley. She founded Theranos, hyped the fraudulent blood testing scam and became for a short time a billionaire. Now all of that is gone, gone, gone. ...more

Leadership Lessons from Antarctic Explorers and Adventurers

by Thomas Fox on

Henry Worsley and Ernest Shackleton are related by more than blood. They are related by their souls. A distant relative, Frank Worsley had accompanied Shackleton on his Antarctic expeditions, including the abortive Nimrod...more

Compliance Needs to Understand Business

by Michael Volkov on

A chief compliance officer needs to be independent and have adequate authority within the organization. But do not get confused by the concept of independence. Compliance depends on collaborative relationships with other...more

Brand’s Memo and Dan’s Desk

Last month, then-Associate Attorney General Rachel Brand issued a memorandum to Department of Justice civil lawyers concerning the circumstances under which they may and may not use federal agencies’ “guidance documents” in...more

Farewell to John Reed, the Death of Pennoyer v. Neff and the Elbit FCPA Enforcement Action

by Thomas Fox on

The bane of every first-year law student, at least in Civil Procedure, is Pennoyer v. Neff. This is because (1) it is usually studied very early in the semester; (2) is viewed as the first true introduction to how strikingly...more

DOJ Announces Intent To Apply Principles From FCPA Corporate Enforcement Policy To Other White Collar Contexts

by Shearman & Sterling LLP on

At the recent American Bar Association’s National Institute on White Collar Crime, the Department of Justice’s (“DOJ”) Acting Head of the Criminal Division, John Cronan, announced that the Criminal Division will use the FCPA...more

This Day in White Collar History: Remembering Henry Friendly

Henry Friendly still has my vote for the title of greatest American judge who ever served at any level. It’s the country’s misfortune that he never served on the U.S. Supreme Court. He did, however, spend nearly thirty years...more

Sapin II and French Anti-Corruption Enforcement

by Michael Volkov on

As more countries enter into the anti-corruption enforcement world, companies face exponential risks of detection and enforcement. Recently, Deputy Attorney General Rosenstein has commented on the need to avoid unfair...more

The SFC's enforcement priorities for 2018

by Hogan Lovells on

In late February, the SFC published its Enforcement Reporter setting out its enforcement priorities and approaches for 2018. The SFC emphasized its enhanced cross-divisional collaborative approach with more targeted...more

Cryptocurrencies and the fight against money laundering

As the global use of cryptocurrencies continues to gather momentum, what are the potential risks and implications for compliance professionals and how can they stay a step ahead of money launderers?...more

Agile Compliance = Operationalized Compliance: Part III – Incentives, Recruiting and Development

by Thomas Fox on

As most of you know, when I get interested in something I can get carried away writing about it and it has happened again as I have been exploring the intersection of agile concepts for business processes and...more

White Collar Crime Alert -The French Prosecutor Office has Entered into the First French DPAs for Corruption Charges

On Feb. 23, 2018, a couple of months after the first French DPA (“CJIP - convention judiciaire d’intérêt public”) in history was entered into between the French prosecutor office and HSBC Private Bank Suisse in relation to...more

Dorsey Anti-Corruption Digest - March 2018

by Dorsey & Whitney LLP on

Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey...more

DOJ Criminal Division Announces FCPA Corporate Enforcement Policy Provides Nonbinding Guidance for All Criminal Cases

On March 1, 2018, John P. Cronan, the acting head of the Department of Justice’s Criminal Division, and Benjamin Singer, Chief of the Fraud Section’s Securities and Financial Fraud Unit, announced at the American Bar...more

Agile Compliance = Operationalized Compliance: Part II – Compliance Teams

by Thomas Fox on

I continue my exploration of how an agile approach can bring innovation to a corporate compliance function. Yesterday I considered how agile concepts can be used to more fully operationalize a compliance function through...more

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