Department of Treasury Archives - Corruption, Crime & Compliance

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...

Uncategorized

3 May, 2016

Revisiting FinCEN’s Proposed Regulations on Beneficial Ownership

You don’t need a weatherman to know which way the wind blows. – Bob Dylan, Subterranean Homesick Blues Political winds are important for a number of reasons. When working in the government, you have to seize the political opportunities to advance practical proposals. When it comes to requiring banks and financial institutions to collect beneficial ownership information from account holders and customers, the Panama Papers...

General

23 Sep, 2015

Checking In on Sanctions Enforcement

The Department of Treasury’s Office of Foreign Asset Control continues to ramp up sanctions enforcement. Even with the likely relaxation of the Iran and Cuba sanctions, OFAC has been continuing its aggressive enforcement program. Thus far, OFAC has collected approximately $270 million in civil penalties, and participated in several major criminal investigations, including Commerzbank and Schlumberger. Commerzbank agreed to pay a total of $1.45 billion...