Two weeks ago, the Department of Justice (“DOJ”) announced two significant enforcement actions and shut down NetWalker and Emotet, powerful tools that had been used by alleged criminal networks engaging in widespread...more
During a roundtable at the Fifth International Debarment Colloquium last month, Joseph Mauro, a spokesperson for the Compliance Unit of the World Bank Group’s (“World Bank”) Integrity Vice Presidency (“INT”), announced recent...more
On October 8, 2020, the Attorney General’s Cyber-Digital Task Force (“the Task Force”) issued its Cryptocurrency Enforcement Framework (the “Report”), which offers background on virtual assets, enforcement milestones, and...more
10/22/2020
/ AML/CFT ,
CFTC ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Currency ,
FATF ,
Federal Reserve ,
IRS ,
Money Laundering ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities and Exchange Commission (SEC) ,
Virtual Currency
On September 10, 2020, the Commodity Futures Trading Commission (“CFTC”) Division of Enforcement released its long-awaited “Guidance on Evaluating Compliance Programs in Connection with Enforcement Matters,” which will be...more
In a significant move toward more transparency, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) released new guidance (the “Guidance”) on August 18, 2020, setting forth its enforcement approach and...more
8/24/2020
/ Bank Secrecy Act ,
Chief Compliance Officers ,
Civil Monetary Penalty ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FinCEN ,
New Guidance ,
Piling-On ,
Remediation ,
Self-Reporting ,
U.S. Treasury
On Friday, July 17, 2020, Special Inspector General for Pandemic Recovery (SIGPR) Brian D. Miller and U.S. Attorney for the Eastern District of Virginia (EDVA) G. Zachary Terwilliger announced a formal partnership to pursue...more
On June 25, 2020, Novartis AG, a Swiss multinational pharmaceutical company, and two subsidiaries reached a combined $345 million resolution with the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange...more
7/16/2020
/ Bribery ,
Cease and Desist Orders ,
Corporate Counsel ,
Department of Justice (DOJ) ,
DPA ,
Foreign Corrupt Practices Act (FCPA) ,
Health Care Providers ,
Novartis ,
Pharmaceutical Industry ,
Popular ,
Securities and Exchange Commission (SEC) ,
Vietnam
On July 3, 2020, the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) published the Second Edition of “FCPA: A Resource Guide to the U.S. Foreign Corrupt Practices Act” (the “Guide”)....more
In early June, federal agencies brought some of the first enforcement actions against COVID-19 securities fraudsters, involving over $100 million in fraudulent claims and profits, making good on their promise to investigate...more
In a novel and aggressive move likely aimed at garnering goodwill with federal regulators, Venezuelan state-owned entity CITGO Petroleum Company (“CITGO”) has sued its former agent for harm CITGO alleges was caused by the...more
6/4/2020
/ Asset Recovery ,
Bribery ,
Citgo ,
Crime Victims ,
Criminal Liability ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Oil & Gas ,
Popular ,
Venezuela
In a little-noticed move yesterday, the U.S. Department of Justice (“DOJ” or “Department”) quietly amended its most important guidance document on corporate compliance. While the updates are far from a dramatic overhaul, they...more
Scrutiny into Paycheck Protection Program Loans Intensifies — Attracts SEC Attention-
Public companies applying for Paycheck Protection Program (“PPP”) loan funds have been under increasing political and media scrutiny....more
On April 14, 2020, for the first time, the Department of Justice (“DOJ”) published a list identifying all corporate monitors actively engaged by companies as a part of criminal resolutions with the Criminal Division’s Fraud...more
The COVID-19 pandemic has caused enormous pain and financial harm and it will take months, or even years, before we know its full impact. As of the time that this article is published, there will be over 1.4 million known...more
As previously noted by the V&E Report, enforcement of the Foreign Agents Registration Act (“FARA”) is on the rise due to recent concerns about covert foreign influence in U.S. politics and elections, and one industry has been...more