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Brink’s Global Services Faces Major Fines: The DOJ and FinCEN Crackdown on AML Violations

Brinks Global Services USA (“BGS USA”), a global leader in secure logistics, found itself at the center of a significant regulatory investigation due to its failure to meet anti-money laundering (“AML”) obligations....more

Antitrust Enforcement in the Procurement Space During the Second Trump Administration

Although the scope of federal antitrust enforcement under the second Trump administration remains uncertain, the Procurement Collusion Strike Force (PCSF) is expected to remain active. The PCSF, which was started by the first...more

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado...more

FinCEN Issues Supplemental Advisory on Fentanyl Distribution and Growing Role of Transnational Criminal Organizations

On June 20, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a supplemental advisory to alert U.S. financial institutions about emerging trends in the illicit fentanyl supply chain. The supplemental advisory...more

DOJ Bolsters International Cooperation to Combat Corruption

Summary - The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...more

Safe Harbor Policy Incentivizes Disclosure of Acquired Companies’ Misconduct

Summary - Deputy Attorney General Lisa O. Monaco unveiled Wednesday, Oct. 4, the Department of Justice’s (DOJ) new safe harbor policy for voluntary self-disclosures (VSD) arising from mergers and acquisitions (Safe Harbor...more

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