Tagged: transaction monitoring

FCPA Enforcement Ramping Up Against Private Equity and Hedge Funds (Part III)

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 fund industry. The Och-Ziff action was initiated in response to the SEC’s industry inquiry launched in 2011. The SEC issued inquiry letters to approximately 10 separate private equity/hedge funds, and investment banks. The results of these inquiries are unknown...

Och-Ziff Failures in Due Diligence and Transaction Compliance (Part II)

The Och-Ziff enforcement action is replete with examples of failures in due diligence and transaction monitoring compliance. Och-Ziff’s bribery schemes were elaborate and intricate and involved complex transactions, particularly in the Democratic Republic of the Congo (DRC), designed to funnel large bribery payments. In the DRC, Och-Ziff executed the scheme primarily through two senior employees and an Israeli partner (DRC Partner), who were committed to...