June 09, 2020 ABAC, anti-bribery, anti-corruption, best practices, compliance, Covid-19, IMF, OECD, World Bank

A new reality is unfolding due to the significant changes that societies all around the world have experienced as a result of the effects of the COVID-19 global pandemic.  While public and private sector entities have taken measures to deal with the destabilizing effect of the pandemic, organizations and experts focused on anti-bribery and anti-corruption have sounded the alarm bells. This is probably most apparent from the statements made by organizations such as the World Bank, IMF, OECD’s Working Group on Bribery and some of the measures they are putting in place and exploring.

Read More

SFO Handbook Update: An In-depth Look

May 27, 2020 best practices, compliance, SFO guidance

What Does the SFO Handbook Update on Evaluating Compliance Programs Tell Us About Designing an Effective Compliance Program? The UK’s Serious Fraud Office (“SFO”) updated its Operational Handbook to include a chapter on Evaluation of Compliance Programs on January 17, 2020 (“the SFO Guidance”). Many analysts have reviewed the 8-page […]

Read More

Increased AML Enforcement in Europe (Part 2 of 2)

April 08, 2020 aml, aml enforcement, EU, europe, financial crime

EU officials are still working on re-introducing a controversial fincrime compliance blacklist of “high-risk third countries” to help financial service firms better risk-assess certain jurisdictions for financial crime threats.

Read More

Sapin II in Practice: Our First Look

August 06, 2019 ABAC, AFA, Sapin II

What are the key failures and program trends OFAC has highlighted in major enforcement actions against financial institutions and corporations?

Read More

In what appears to be a flurry of updates and newly-issued regulatory guidance (see Steele’s coverage of OFAC guidance and DOJ’s Evaluation of Corporate Compliance Programs), the Financial Industry Regulatory Authority (“FINRA”) has just issued Regulatory Notice 19-18 (the “Notice”) to provide guidance to member firms regarding suspicious activity monitoring and reporting obligations under FINRA Rule 3310 (Anti-Money Laundering Compliance Program).

Read More