We should all admit something (among many things) — reading through factual statements of bribery offenses, the facts all start to meld together. Criminals are not as ingenuous or creative as they think, and the schemes they employ are fairly straightforward. Let’s start with one profound grasp of the obvious — To pay bribes, criminals have to “steal” money from the company, that is, they...
J&F Investimentos (“J&F”) FCPA settlement presents a number of important lessons learned. While the bribery scheme was brazen and involved a large amount of money, the techniques and warning signs must have been fairly obvious. Despite J&F’s large global operations and expansion plans, J&F made no apparent effort to build an ethics and compliance program or implement basic compliance requirements, such as a Code of...
Anti-money laundering professionals are in for a rude awakening. Know Your Customer or KYC requirements are currently kicking up a notch, and will be even more dramatic when the new FinCEN beneficial ownership regulations become effective in 2018. Financial regulators have become much more sophisticated since the financial crash, and the industry should expect even greater regulatory demands. As financial scandals continue to pop up...
When Senator Levin, the Democrat from Michigan, announced his retirement from the Senate in 2014, you could hear a collective sigh of relief from the corporate business community. Senator Levin had dedicated himself to investigating our tax system and how corporations were able to avoid taxes through offshore accounts. With the recent release of the Panama Papers, Senator Levin would have found even more evidence...
The media loves a scandal. In the banking and compliance world, the latest scandal to hit the media was the Panama Papers. The Panama Papers is surprising in scope – Panama has become the favorite financial haven for money launderers, PEPs and other miscreants. We have all seen this in the business world as Panamanian banks grew in rapid fashion. As the Cayman Islands, Switzerland...
