AML Risks and Foreign Correspondent Banking
May 30 2016 With the Panama Papers scandal and government promises of continued aggressive AML enforcement, financial institutions face a variety of risks that…
Know Your Customer (“KYC”) due diligence best practices
July 9 2015 Financial institutions have a lengthy list of Anti-Money Laundering compliance requirements. They face a mountain of risks from a large number of…
The Demise of Valeant Pharmaceuticals: A Case Study in Rotten Culture and Business Ethics
April 3 2016 Showing my age again, Woody Allen’s Take the Money and Run included a hilarious scene when Woody’s parents wearing Groucho Marx glasses talk about…
Convergence of Audit and Compliance Functions
June 28 2016 Humans have a tendency to make things more complicated than they really are. To capture the flavor of my sentiment, all you need to do is watch the…
Who is Responsible for a Company’s Mood in the Middle? - the Wells Fargo Fiasco
September 26 2016 Wells Fargo's cultural tone is not easily segregated between "top," "middle" and "bottom." Despite the recent cross-selling scandal, in which the…
DOJ “Tweaks” FCPA Corporate Enforcement Policy
March 26 2019 The Justice Department is wedded to its FCPA Corporate Enforcement Policy (excuse me for the use of “wedded,” we recently celebrated our son’s…
2019 Cryptocurrency Regulations - A Primer and What to Expect Throughout the Year
March 14 2019 You've heard this before, but it still holds true - cryptocurrency regulations are coming. Everyone knows they're inevitable, and there has been some…
FCPA Enforcement Ramping Up Against Private Equity and Hedge Funds (Part III)
October 11 2016 The Och-Ziff settlement has now set the stage for the Justice Department and the SEC to focus its enforcement eye on the private equity and hedge…
Och-Ziff Failures in Due Diligence and Transaction Compliance (Part II)
October 10 2016 The Och-Ziff enforcement action is replete with examples of failures in due diligence and transaction monitoring compliance. Och-Ziff’s bribery…
DOJ and SEC Deliver Body Blow to Private Equity and Hedge Funds: Och-Ziff Settles FCPA Violations for $412 Million (Part I)
October 9 2016 The Justice Department and the Securities Exchange Commission delivered a powerful FCPA enforcement message to private equity and hedge funds…
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