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Banking Sector Corruption Compliance

Thomas Fox - Compliance Evangelist

10 For 10: Top Compliance Stories For the Week Ending June 7, 2025

Welcome to 10 For 10, the podcast which brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance brings to you, the compliance professional, the compliance stories you need to...more

Thomas Fox - Compliance Evangelist

10 For 10: Top Compliance Stories For the Week Ending April 26, 2025

Welcome to 10 For 10, the podcast which brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance brings to you, the compliance professional, the compliance stories you need to...more

Womble Bond Dickinson

Navigating the Labyrinth: Artificial Intelligence in the Battle Against Trade-Based Money Laundering

Womble Bond Dickinson on

In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more

White & Case LLP

The Wolfsberg Group's Updated Anti-Corruption Guidance – The New Global Threshold?

White & Case LLP on

On April 17, 2023, the Wolfsberg Group (the "Group") issued updated guidelines for financial institutions ("FI") relating to Anti-Bribery and Corruption ("ABC") Compliance Programs. Although the guidance is not binding, it...more

The Volkov Law Group

UK Bank Agrees to Pay $4 Million to Settle OFAC Sudanese Sanctions Violations

The Volkov Law Group on

Last week, British Arab Commercial Bank (BACB), located in the United Kingdom, agreed to settle an OFAC enforcement action for $4 million. ...more

Thomas Fox - Compliance Evangelist

Farewell to the Easy Rider and How to Scandal Proof Your Company: Part 1

Fonda’s life informs today’s blog post as we begin a multi-part series based upon the recent Harvard Business Review (HBR) Spotlight on White Collar Crime. Today, we begin the article by Paul Healy and George Serafeim,...more

Thomas Fox - Compliance Evangelist

Flame On-Tribute to the Fantastic Four: Part II – Four Issues from the FCPA Corporate Enforcement Policy

Yesterday, I considered four questions which the Department of Justice (DOJ) may ask Goldman Sachs. Today I want to consider what the company must show under the FCPA Corporate Enforcement Policy....more

Thomas Fox - Compliance Evangelist

The Credit Suisse FCPA Enforcement Action: Part III – The Result and Going Forward

Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more

Thomas Fox - Compliance Evangelist

The Credit Suisse FCPA Enforcement Action: Part II – The (Very) Bad Facts

Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more

Thomas Fox - Compliance Evangelist

The Credit Suisse FCPA Enforcement Action: Part I – Background

Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more

The Volkov Law Group

Lessons Learned from Credit Suisse Corrupt Hiring Scheme and FCPA Settlement (Part II of II)

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Credit Suisse has joined the ranks of other banks and companies that have settled FCPA violations involving hiring of government officials’ relatives in exchange for business benefits, including JPMorgan Chase; BNY Mellon,...more

Thomas Fox - Compliance Evangelist

Nights in White Satin – The Continued Pain at Wells Fargo

The Wells Fargo scandals continue to be one of the starkest lessons about the cost of a corrupt culture and the catastrophic effect it can have on an organization. The former Chief Executive Officer (CEO) and head of the...more

The Volkov Law Group

Financial Institutions and the Glaring Absence of an Ethical Culture

The Volkov Law Group on

Federal prosecutors and regulators have been active in tackling US banks. In the last few weeks, the Federal Reserve took the extraordinary step of blocking Wells Fargo’s ability to grow its business until it improves its...more

Thomas Fox - Compliance Evangelist

Star Wars Week: Part III – Return of the Jedi – A good final result

While I am not sure how much celebrating HSBC might be doing this week, they should have pride in making it through the five-year DPA. The bank worked very hard to overcome its miss-steps and hopefully it will continue to do...more

Thomas Fox - Compliance Evangelist

More Compliance Lessons from Wells Fargo-FOREX Trades

At some point, you must ask just how corrupt is an organization? What does the tone from top which says to make your numbers at all cost, translate to in operationalization? Unfortunately, we have seen yet another dramatic...more

The Volkov Law Group

It Takes a Village . . . To Commit Bribery

The Volkov Law Group on

A company that commits bribery has to undergo a soul-searching examination of its operations, from top to bottom. Bribery violations come in all shapes and forms – systemic violations like Siemens, Daimler and other...more

The Volkov Law Group

Tales from the Corporate Scandal Crypt: GM, VimpelCom, VW and Wells Fargo

The Volkov Law Group on

We are fascinated by corporate scandals. Since the 1980s, the US public has enjoyed unraveling corporate scandals, and vilifying corporate leaders caught in the web of deceit and misconduct. I am sure there are historical...more

Thomas Fox - Compliance Evangelist

Why Compliance Must Manage Risk

What is risk to your company? In the anti-corruption world, it is conduct which might violate the Foreign Corrupt Practices Act (FCPA), UK Bribery Act, Brazilian Clean Companies Act or one of the other internationally focused...more

The Volkov Law Group

Aggressive Remediation: Embraer and JP Morgan

The Volkov Law Group on

There is no question that the Justice Department has raised compliance program expectations in a number of areas. Whatever you may think about the efficacy or fairness of the FCPA Pilot Program, the Justice Department has...more

Thomas Fox - Compliance Evangelist

JPMorgan Sons and Daughters FCPA Enforcement Action, Part II

Today I will consider the superior result achieved by JPM in its FCPA resolution. Not only did it receive a 25% discount off the bottom of the US Sentencing Guidelines fine range but it received a NPA and not even a Deferred...more

Thomas Fox - Compliance Evangelist

Three Key Questions to Ask in Hiring of Family Members of Foreign Officials

One of the top academic commentators in the anti-corruption space is Matthew C. Stephenson, co-founder of the Global Anticorruption Blog. I was intrigued by Stephenson’s piece, entitled “Does an FCPA Violation Require a Quid...more

Thomas Fox - Compliance Evangelist

Froome Ends Tour With Win; JP Morgan to End Sons and Daughters Case?

I begin today’s post with a tip of the (cycling) helmet to Englishman Chris Froome who yesterday won his third Tour de France championship. Froome overcame a great many obstacles, not the least of which was being involved a...more

K&L Gates LLP

DOJ Sharpens Focus on Corporate Compliance in Deciding Whether to Prosecute Companies

K&L Gates LLP on

One of the factors that the U.S. Department of Justice (DOJ) considers in deciding whether to bring charges against a corporation is the existence and effectiveness of the corporation’s pre-existing compliance program. On...more

Thomas Fox - Compliance Evangelist

Reflections on the Hitachi FCPA Enforcement Action

Earlier this week, the Securities and Exchange Commission (SEC) announced resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Hitachi Ltd (Hitachi). There were several interesting aspects to...more

The Volkov Law Group

Hiring Practices: A New or Old FCPA Compliance Challenge?

The Volkov Law Group on

Contrary to the opinion of many in the FCPA space, the BNY Mellon settlement and the looming actions against six major financial institutions for hiring practices is not a big shock or surprise. The SEC is not raising a new...more

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