The Justice Department’s foreign bribery resolution with The Scoular Company, an Omaha, Nebraska-based agricultural supply chain company, is one of the more unusual FCPA cases in recent memory. It did not arise from a company chasing a government contract or a licensing decision abroad. It arose from routine cross-border logistics, corn and other agricultural shipments moving from the United States into Mexico, and a bribery...

Every so often, corporate governance debates that we thought were settled come roaring back. The reporting line for the chief compliance officer is one of them. For years, the trend line pointed in the right direction — more companies elevating the CCO to report directly to the CEO, with independent access to the board. Lately, I am seeing troubling signs of backsliding, with companies quietly...

The individual prosecutions now flowing out of the TD Bank money laundering scandal are a reminder that institutional control failures are ultimately executed, or ignored, one employee at a time. This week, U.S. District Judge Esther Salas sentenced former TD Bank assistant manager Wilfredo Aquino to 46 months in prison and three years of probation for his role in a money laundering conspiracy that moved...

The SEC’s latest enforcement action against Merrill Lynch is a reminder that a transaction monitoring system is only as good as the calibration behind it. On July 1, 2026, Merrill agreed to pay a $7.5 million civil penalty, accept a censure, and consent to a cease-and-desist order to settle SEC charges that it failed to file numerous Suspicious Activity Reports (SARs) between April 2020 and...

On June 30, 2026, EagleBank agreed to pay more than $9.7 million to resolve a Bank Secrecy Act investigation into more than a decade of willful AML/CFT program failures tied to a check kiting scheme run by a father-son pair with a personal relationship to the bank’s own former chairman and CEO. The Justice Department’s non-prosecution agreement with EagleBank and its parent, Eagle Bancorp Inc.,...