AML and FCPA “Due Diligence”: Apples and Oranges?

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3 Responses

  1. Kevin L. Warmack, E.J.D. says:

    In the same vein, when looking at suitability, the same question of due diligence also applies. An account could be considered suitable for a particular transaction but then at the same time the account could be considered at risk for money laundering violations as well as FCPA violations. In all cases, as much as you’d like to put them all together, you have to look at each item in its own context.

  2. Pyotr Maghdashyan says:

    Thanks for the article. While I agree with the idea as a whole, it is also true that due diligence for both AML and FCPA share the most important about the procedure, which is obtaining knowledge and making a decision. In that respect, choice of tools to reach this goal is pretty often the same for both purposes, just like the underlying factor in making a decision – common sense. Besides, I’d still think that drug trafficking is a huge red flag in FCPA matters as well, as though not directly related to corruption, but that’s an illegal activity of a scope large enough to keep many out of doing business with someone engaged in it.

  1. July 2, 2012

    […] on recent remarks at a conference from the new director of the Serious Fraud Office. Mike Volkov considers whether anti-money laundering and FCPA due diligence are as similar as apples and oranges, and […]