Tagged: Independent compliance monitor

What Can We Expect in Future FCPA Enforcement Actions?

In the FCPA and white collar defense community, we have seen buckets and buckets of ink spilled on the coming wave of aggressive enforcement.  Justice Department officials have made so many statements about the “new” approach to prosecuting white collar crime.  The government moves slowly and implementing far-reaching changes takes time.  Anyone who has worked at DOJ knows that change is never immediate but takes...

Episode 220 — DOJ NatWest Markets Fraud Spoofing Enforcement Action

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 non-prosecution...