News & Analysis as of

BSA/AML Compliance Corporate Governance

Thomas Fox - Compliance Evangelist

Levels of Due Diligence

Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption risk. The key is to develop a mechanism to determine the appropriate level...more

The Volkov Law Group

DOJ Outlines Aggressive White Collar Enforcement Measures and New Compliance Expectations (Part I of II)

The Volkov Law Group on

The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement.  Last week, Lisa Monaco, DOJ’s...more

Mitratech Holdings, Inc

Reduced Cost and Enhanced Impact: Embedding Compliance in BAU

Compliance management has moved from being a nice to have, to an absolute need to have. For many organizations, it is part of business-as-usual (BAU). The scale and scope of compliance frameworks across the world have grown,...more

Thomas Fox - Compliance Evangelist

A Cheater is a Cheater and a Stinker is a Stinker

Something is very rotten in both Denmark around its banks regarding AML and the Houston Astros and their leadership. Before and during the World Series, Astros management engaged in either some of the most boneheaded conduct...more

Thomas Fox - Compliance Evangelist

The OFAC Compliance Framework: Element 4 & 5 – Testing and Auditing & Training

After a short visit to Val Lewton’s Cat People, I return to conclude this multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand...more

Katten Muchin Rosenman LLP

Corporate Financial Weekly Digest, Featuring Topics on CFTC, Banking, Executive Compensation and ERISA, and UK/EU Developments

CFTC - NFA Proposes Amendments to Compliance Rule 2-9(c) and Interpretive Notice: Compliance Rule 2-9: FCM and IB Anti-Money Laundering Program - On June 15, the National Futures Association (NFA) submitted to the...more

The Volkov Law Group

AML Compliance Lessons Learned from US Bancorp and Rabobank Enforcement Actions

The Volkov Law Group on

Global banks have been the focus of enforcement actions, focusing on AML and sanctions violations.  With the new beneficial ownership regulations effective May 11, 2018, we are about to see a significant transformation in AML...more

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