Public-Private Partnerships to Stem Corruption
Episode 339: Four Sanctions Cases Everyone Should Know
The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
Wicked Coin: The "Fat Leonard" Scandal
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
RICO Vicarious Liability — RICO Report Podcast
Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm
RICO Damages — RICO Report Podcast
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 305 -- Deep Dive into SAP FCPA Settlement
AGG Talks: Antitrust and White-Collar Crime Roundup - Developments in the Trump Indictments and Recent Supreme Court Issues
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
2024 represents the 25th anniversary of the Organisation for Economic Co-operation and Development (OECD) Convention on Combating Bribery of Foreign Public Officials, which has now been signed by 46 countries—including eight...more
On April 15, 2024, the Department of Justice released its “Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals.” Similar in many ways to programs introduced earlier this year by the U.S. Attorney’s...more
Since the Corporate Transparency Act took effect on January 1, 2024, scammers have seized the opportunity to send notices to owners of recently formed companies offering “filing services.” In response to these scams, FinCEN...more
On March 1, 2024, Judge Liles C. Burke of the Northern District of Alabama, Northeastern Division, ruled in U.S. v. Yellen that the Corporate Transparency Act (the “Act”) is unconstitutional. The federal district court found...more
On March 1, 2024, the United States District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (CTA) exceeds the constitutional limits on Congress’s legislative power and is therefore...more
The Financial Crimes Enforcement Network (FinCEN) of the US Treasury Department has issued a final rule (Final Rule) implementing the beneficial ownership reporting requirements of the Corporate Transparency Act (together...more
Thanks to the Corporate Transparency Act, starting Jan. 1, 2024, all companies created in the United States must complete a new form with the Treasury Department’s Financial Crimes Enforcement Network, commonly known as...more
The Corporate Transparency Act (“CTA”) is a newly effective federal law that requires certain entities to report their owners to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”). Below are...more
On December 14, the Department of Justice (DOJ) announced that Freepoint Commodities LLC, a Connecticut-based commodities trader, had agreed to a three-year deferred prosecution agreement (DPA) to resolve a DOJ investigation...more
Earlier this month, a Regulatory Commission issued a significant decision limiting the scope of liability for misconduct under the FA Rules. In dismissing the FA’s charge against Arsenal FC manager Mikel Arteta, the...more
CTA Denial #3: “My industry’s lobbyists would never allow such a law to get passed.” Lobbyists had staved off attempts to implement the CTA, and its predecessor bills, for decades....more
Beginning January 1, 2024, certain privately held companies, known as “reporting companies,” will be required to file a Beneficial Ownership Information (BOI) Report to identify, and provide personal information about, their...more
The purpose of the Corporate Transparency Act isto “better enable critical nationalsecurity, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other illicit activity” by...more
Introduction - Doing business with China is always complex. Add in the need for compliance with the Foreign Corrupt Practices Act (FCPA) and the challenges can be formidable. Companies operating in or with ties to China must...more
The Corporate Transparency Act (the “CTA”), which takes effect on January 1, 2024, will require many companies to report certain beneficial ownership information to the Financial Crimes Enforcement Network (“FinCEN”), a...more
CTA Denial #1: “I am a sophisticated business owner, and I have never heard of this.” The enactment of the CTA in 2021 came as a shock to many (to some, a much later aftershock)....more
Despite the excitement that surrounded original cryptocurrencies like Bitcoin, the dust eventually settled, revealing that only a few early investors got rich and many others lost their life savings. But it was not long...more
The Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued final regulations to implement the reporting requirements under the federal Corporate Transparency Act (CTA). The CTA aims to further...more
Corporate compliance professionals can learn a lot from the audit world. Our latest lesson comes in a statement from the Securities and Exchange Commission, warning auditors to do better at identifying the risk of fraud among...more
In this post we discuss disclosure obligations under Canadian economic sanctions and anti-terrorism laws, including in respect of financial services providers. As discussed below: There are disclosure obligations...more
FinCEN ha estado ocupada en la búsqueda de combatir la corrupción, como lo demuestra la emisión consecutiva de Avisos de Propuesta de Reglamentación (“NPRMs”). El 6/12/21, emitieron el (Proceso regulatorio para los nuevos...more
FinCEN has been busy in the quest to fight corruption as evidenced by back-to-back issuance of Notices of Proposed Rulemaking (NPRMs). On 12/6/21, they issued the (Regulatory Process for New Real Estate Sector Reporting...more
2020 saw continuity in CFTC leadership, programs, and direction from 2019. Overall, the Commission enjoyed an unusually heavy rulemaking calendar and continued the direction of its enforcement program from 2019. On the...more
The former deputy finance chair of the Republican National Committee and prominent fundraiser for President Trump has agreed to plead guilty with lobbying on behalf of Jho Low, an indicted and fugitive financier, who was...more
COVID-19 is changing the nature of corruption and fraud. The risks they bring are mutating, and the pandemic is drastically altering the way such risks are detected and mitigated. ...more