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FIRREA: Second Circuit Erases Trial Verdict and $1.27 Billion FIRREA Penalty Due to Justice Department’s Failure to Prove Fraud
  • Fried Frank Harris Shriver & Jacobson LLP
  • USA
  • May 24 2016

On Monday, the Second Circuit Court of Appeals delivered a blow to the Justice Department’s increasing use of the Financial Institutions Reform


FinCEN Issues Final Customer Due Diligence Rule
  • Fried Frank Harris Shriver & Jacobson LLP
  • USA
  • May 13 2016

On May 11, 2016, the U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN) published a final rule under the Bank Secrecy Act that


New York Department of Financial Services Proposed Rule to Increase AML and Sanctions Compliance Requirements
  • Fried Frank Harris Shriver & Jacobson LLP
  • USA
  • March 28 2016

The New York State Department of Financial Services (DFS) has recently proposed a new anti-money laundering and anti-terrorism regulation that would


Accidental tipping: the wrong kind of holiday present for family and friends
  • Fried Frank Harris Shriver & Jacobson LLP
  • USA
  • December 14 2012

With the holidays underway, and as celebrations with family and friends are filling the calendar, we take this opportunity to wish you a happy holiday season and to encourage you to talk about something other than nonpublic work news during your festivities


Treasury department revisits anti-money laundering rules for investment advisers
  • Fried Frank Harris Shriver & Jacobson LLP
  • USA
  • November 18 2011

In a long-awaited development, James H. Freis, Jr., Director of the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”), announced at an anti-money laundering (“AML”) conference this week that FinCEN is “revisiting the topic of investment advisers” and drafting a rule proposal that would require certain investment advisers to establish and implement AML programs


OFAC announces settlements in significant sanctions enforcement cases
  • Fried Frank Harris Shriver & Jacobson LLP
  • USA
  • November 13 2015

In the last month, the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC") has announced two significant settlements related to


Civil False Claims Act: D.C. Circuit decisively rejects Justice Department attempts to impose FCA liability based on noncompliance with ambiguous agency regulation
  • Fried Frank Harris Shriver & Jacobson LLP
  • USA
  • November 25 2015

The long-running False Claims Act ("FCA") saga of Moving Water Industries ("MWI") is finally reaching an end. After battling against what it


New York’s Department of Financial Services announces additional $315 million penalty against Bank of Tokyo-Mitsubishi UFJ, Ltd. for allegedly misleading regulators, continuing its focus on U.S. sanctions and international antimoney laundering enforcement
  • Fried Frank Harris Shriver & Jacobson LLP
  • USA
  • November 21 2014

On November 18, 2014, New York's Department of Financial Services ("DFS") announced another major settlement with the Bank of Tokyo-Mitsubishi UFJ


Court’s $1.3 billion judgment against Bank of America signals FIRREA’s potential role as a powerful substitute for the False Claims Act in financial fraud cases
  • Fried Frank Harris Shriver & Jacobson LLP
  • USA
  • August 1 2014

In a much-anticipated ruling applying the civil penalties provision of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989, 12 U


Search warrants for business premises: a practical guide for preparation
  • Fried Frank Harris Shriver & Jacobson LLP
  • USA
  • November 29 2010

In connection with a high-profile insider trading investigation, the United States Attorney's Office for the Southern District of New York and the Federal Bureau of Investigation utilized search warrants to raid the offices of three hedge funds on November 22