Corruption, Crime & Compliance

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6 Jan, 2022

FinCEN Issues Proposed Beneficial Ownership Reporting Regulations

The Anti-Money Laundering Act of 2020 was a game-changing piece of legislation. Perhaps the most important provision is the expansion of beneficial ownership regulatory authority. Following up on this important issue, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued its Notice of Proposed Rulemaking to implement new beneficial ownership reporting requirements. In the international sphere of AML compliance and enforcement, the United States has...

General

5 Jan, 2022

NatWest’s Fraudulent “Spoofing” Schemes (Part II of II)

NatWest’s fraudulent “spoofing” schemes occurred in the primary and secondary markets for U.S. Department of Treasury Securities, including derivatives that tracked the prices of U.S. Treasury Securities for 5-year, 10-year and 30-year Treasury notes and bonds. Between January 2008 and May 2014, a NatWest trader in London (Trader-1) and NatWest’s broker-dealer in Stanford (trader-2) engaged in a number of schemes to defraud relating to the...

General

4 Jan, 2022

NatWest Markets Pleads Guilty and Agrees to Pay $35 Million for Fraudulent “Spoofing” Scheme (Part I of II)

The Department of Justice secured a guilty plea from NatWest Markets, the newly-named Royal Bank of Scotland, for trade manipulation, referred to as “spoofing,” in U.S. Treasury markets. The NatWest resolution reflected new changes in DOJ’s white collar enforcement policies, including acknowledgement and consideration of NatWest’s prior misconduct (criminal and civil) and appointment of an independent compliance monitor. NatWest was not offered a deferred or...

General

23 Dec, 2021

Happy Holidays

The Volkov Law Group wishes our clients, colleagues, subscribers, readers and friends and families a wonderful, happy holiday season. We are grateful for your support and your friendship. We look forward to a New Year filled with hope, recovery, and a bright path forward. Our blog, podcasts and webinars will return after the New Year. Thank you again from all of us at The Volkov...

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21 Dec, 2021

OFAC Collects $133k from a US Individual for Violations of Iran Sanctions Program

In May 2019, OFAC released its Framework for a Sanctions Compliance Program. OFAC announced that it intended to increase the prosecution of individuals for sanctions violations. OFAC has brought two cases against individuals, and last week settled its third case against an individual since its May 2019 announcement. The latest case involves prohibited transactions with Iran relating to the cement clinker business. The individual, a...

General

21 Dec, 2021

United States, European Union, United Kingdom and Canada Coordinate Further Sanctions Against Belarus

In an interesting announcement, the US, EU, UK and Canada implemented additional sanctions against Belarus. The coordinated announcement reflected the Biden Administration’s diplomatic commitment to joint sanctions actions. The strategy is designed to increase the impact of sanctions programs in response to President Lukashenko’s pushing of a humanitarian crisis resulting from the migrant crisis in Eastern Europe. This humanitarian crisis resulted in widespread condemnation by...

General

19 Dec, 2021

Department of Justice Does the Two-Step and Announces Criminal Conspiracy Charges Against Aerospace Executives

When the Department of Justice warns businesses and individuals, everyone needs to listen and respond accordingly. Starting in 2016, the Justice Department’s Antitrust Division warned businesses that the Antitrust Division intended to bring criminal prosecutions for illegal agreements, price-fixing/wage-fixing, in labor markets. No one should be surprised – DOJ has been bringing criminal cases against companies, executives and human resource professionals. In the beginning of...

General

16 Dec, 2021

The United States Strategy on Countering Corruption: Digging into the Anti-Corruption Initiatives (Part III of III)

The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals. Under the third of the five pillars, Holding Corrupt Actors Accountable, the U.S. Government specifically calls out the importance of private sector commitment to anti-corruption compliance programs “to improve the international business climate by encouraging the adoption and enforcement of anti-corruption compliance programs by U.S. and...

General

15 Dec, 2021

The Five Pillars of the New Anti-Corruption Initiative (Part II of III)

The Biden Administration’s new anti-corruption initiative is a significant commitment to the battle against global corruption. According to the Biden Administration, “[c]orruption is a cancer with the body of societies – a disease that eats at public trust and the ability of governments to deliver for their citizens. The deleterious effects of corruption impact nearly all aspects of society.” At the heart of the new...

General

15 Dec, 2021

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...