Tagged: beneficial ownership

Biden Administration Announces New Anti-Corruption Strategy (Part I of III)

The Biden Administration announced a new, comprehensive anti-corruption program, the United States Strategy on Countering Corruption. The new anti-corruption policy is the follow on to the earlier announcement elevating the global anti-corruption battle to a national security concern.  After that announcement, the Biden Administration conducted a 200-day inter-agency examination to develop a comprehensive government-wide anti-corruption initiative. The Biden Administration released the new United States Strategy...

The Coming AML Enforcement Storm

Blog after blog, commentator after commentator, and everyone else who has an opinion has been repeating the same message – the Biden Administration is going to increase enforcement risks.  While these general opinions are correct, a more specific and focused analysis is needed. It is one thing to cite a strong enforcement bent but it is another to watch the key issue – resources.  I...

Episode 178 — The Corporate Transparency Act: Interview of Scott Greytak, Transparency International, and Erica Hanichak, The Fact Coalition

Congress enacted The Corporate Transparency Act, as part of the National Defense Authorization Act.  The CTA expands beneficial ownership disclosure requirements for US entities.  The new disclosure requirements target shell companies and small businesses to ensure disclosure beneficial ownership information. Liz Slim, Senior Counsel at The Volkov Law Group, interviews Scott Greytak from Transparency International USA, and Erica Hanichak from the FACT Coalition and review...

Beneficial Ownership: Identification and Mitigation (Part IV of IV)

We are finally reaching the end of the road on the beneficial ownership path.  In this last posting on the issue (for now), let’s start with a third-party population (third parties, vendors, suppliers) which have been classified into three categories, the first two of which fall into high-risk (foreign government interaction/representation and government ownership).  The bulk of the population, usually around 80 to 85 percent...

Practical Risk-Based Ranking Strategies to Beneficial Ownership Issues (Part III of IV)

At the outset, if you have a headache after reading my first two posts on the beneficial ownership issue, I apologize.  The issues twist and turn depending on whether the situation involves OFAC sanctions or corruption risks, and reflects the variety of ownership situations that occur. Given the overwhelming nature of the burden of a beneficial ownership risk mitigation strategy, we have to return to...

Unraveling Beneficial Ownership Risks (Part II of IV)

When discussing the importance of beneficial ownership with compliance professionals, there is often a disconnect between the theory and reality.  Everyone understands the legal and compliance risks and how they apply to third-parties, vendors and suppliers.  But when a compliance officer considers the burden of uncovering beneficial ownership interests, they quickly resist the need for such an analyses across the population.  And for good reason....

Addressing Beneficial Ownership Requirements in Your Compliance Program (Part I of IV)

We repeatedly hear about the importance of beneficial ownership, and the requirement that companies confirm beneficial ownership of its third-parties, vendors and suppliers.  At the same time, there is increasing pressure from regulators and law enforcement to identify and unravel beneficial ownership when dealing with business partners. There is no question that beneficial ownership is a critical issue.  I have frequently stated (i.e. repeated myself)...

Episode 140 — Addressing Beneficial Ownership Interest Risks in Your Compliance Program (Part I of II)

In a two-part series, Michael Volkov examines the continuing problem of identifying and mitigating beneficial ownership risks.  Money launderers and corrupt individuals continue to rely on corporate structures to disguise their ownership interests to further illicit schemes.  Companies have to develop strategies that practically address the risks without dedicating disproportionate resources to the problem. In the first episode, Michael Volkov discusses beneficial ownership risks and...

Join Us for a May 16, 2019 BVD Webinar: “Is “Power and Control” the New Beneficial Ownership?

What are the new best practices for third-party risk management? Join Michael Volkov, CEO of The Volkov Law Group; Bill Hauserman, Senior Director, Compliance Solutions, Bureau van Dijk, a Moody’s Analytics Company; and Ted Datta, Director, Governance, Risk and Compliance Solutions, Bureau van Dijk, for a live webinar on Thursday May 16, 2019, at 11 am EST/4 pm BST. Please sign up HERE.  New anti-corruption...

Webinar: A Review of FinCEN’s New Beneficial Ownership Regulations

Webinar: A Review of FinCEN’s New Beneficial Ownership Regulations Wednesday, March 28, 2018, 12 Noon EST Sign Up Here After a lengthy implementation period, FinCEN’s new beneficial ownership regulations are about to become effective. Financial institutions are scrambling to meet a May 11, 2018 deadline. FinCEN’s new regulations require financial institutions to implement important new beneficial ownership requirements as part of their customer due diligence...