Episode 377 -- Refocusing Due Diligence on Cartels and TCOs
FCPA Compliance Report: Death of CTA
The Terminator: The QPRT as a Wealth Transfer Strategy and CTA Updates
RoboCop: Overview of Corporate Basics and Compliance Filings
The Corporate Transparency Act
John Wick - What You Need To Know about the Corporate Transparency Act
Cannabis Law Now Podcast: Cannabis Companies and the Corporate Transparency Act
Examining FinCEN FAQs, Proposed Legislation and Other CTA Developments
Navigating the Corporate Transparency Act - Payments Pros – The Payments Law Podcast
John Neiman on the Corporate Transparency Act
Webinar: Corporate Transparency Act
What Nonprofit Leaders Need To Know About the Corporate Transparency Act
Navigating Russia Sanctions
What Will the Corporate Transparency Act Mean for Your Business? [More with McGlinchey, Ep. 30]
Gary Kalman on Corruption and Compliance Programs
Compliance Perspectives: Due Diligence and Ultimate Beneficial Ownership (UBO)
Episode 8 -- The Critical Importance of Beneficial Ownership to Compliance
New register of beneficial ownership of UK real estate
FCPA Compliance Report-Episode 341, Brian Alster on the Problem of Beneficial Ownership
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has significantly increased its focus on sanctions compliance for “financial gatekeepers,” including financial institutions and other firms...more
U.S. sanctions enforcement is evolving to adopt a “control” analysis similar to the analysis employed by the European Union and United Kingdom based on a recent major enforcement action by the U.S. Department of the...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a historic $215,988,868 civil monetary penalty against GVA Capital Ltd. (GVA), a venture-capital firm registered in the Cayman Islands...more
The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) fined GVA Capital Ltd. $215 million, primarily for violating the Ukraine/Russia-related sanctions regulations, when GVA mistakenly concluded that it...more
In the March edition of our Public Company Watch, we cover key issues impacting public companies, including the new climate disclosure rules, SEC scrutiny on beneficial ownership filings, West Palm Beach Firefighters’ Pension...more
El 2/20/23, FinCEN publicó la Guía de Cumplimiento para Pequeñas Entidades para los requisitos de Acceso y Salvaguardas de la información sobre los Beneficiarios Finales. La Guía de BOI Acceso y Salvaguardas (de seis páginas...more
On 2/20/23, FinCEN published the Small Entity Compliance Guide for Beneficial Ownership Information Access and Safeguards Requirements. The (six-pages and four sections) BOI Access & Safeguards Guide provides an overview...more
The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more
In the January Public Company Watch, we cover key issues impacting public companies, including navigating the 2023 20-F season, updated SEC guidance related to confidential treatment applications, the Delaware Court of...more
As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more
TRADE TIP OF THE MONTH: New Companies Have More Time To Report Ownership- The Treasury Department’s Financial Crimes Enforcement Network issued a final rule in late November to delay the deadline for newly created...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
Priorities Echo Prior Alerts and Enforcement Actions - The SEC’s Division of Examinations (the “Division”) released on October 16 a report on its “Examination Priorities” (the “Report”) for fiscal year 2024. This release...more
1. Seagate Technology Gets Largest-Ever BIS Penalty for Sales to Huawei- Seagate Technology LLC recently incurred a $300 million civil penalty from U.S. Department of Commerce’s Bureau of Industry and Security (BIS) due to...more
The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more
We have been closely monitoring the sanctions landscape over the last few months. Back in March, we covered the sanctions levied by the United States and other jurisdictions in response to Russia’s invasion of Ukraine. The...more
The U.S., European Union (EU), United Kingdom (U.K.) and many other countries have imposed similar but not necessarily identical sanctions on Russia. In corporate jet transactions, the sanctions laws of several jurisdictions...more
Our quarterly Financial Crime Horizon Scanner for the US summarizes key financial crime related legal and regulatory changes expected over the next 2 years and provides electronic links to key resources. We hope that you...more
The Regulation Process for FinCEN’s New Beneficial Ownership Reporting Requirement Launches - The Financial Crimes Enforcement Network (FinCEN) issued an Advanced Notice of Proposed Rulemaking (ANPRM) on Thursday to solicit...more
On January 1, 2021, the Senate and the House of Representatives voted to override President Trump’s veto of the National Defense Authorization Act (NDAA) of 2021. The NDAA introduces legislation that allows federal oversight...more
At the outset, if you have a headache after reading my first two posts on the beneficial ownership issue, I apologize. The issues twist and turn depending on whether the situation involves OFAC sanctions or corruption risks,...more
As companies elevate their “game” in sanctions compliance, it is important that compliance officers critically examine the strengths and weaknesses of their compliance programs. Many companies already have a screening...more
In this era of aggressive enforcement, global companies have to integrate beneficial ownership requirements when conducting due diligence of business associates and when engaging customers....more
In the current environment of increased regulation, transparency, reporting and heightened compliance standards, the US and its Government Agencies have an arsenal of tools with extraterritorial application. ...more
LATAM Airlines Agrees to Pay $22 Million to Settle FCPA Cases - Last month, LATAM Airlines (“LATAM”), based in Santiago, Chile, agreed to pay $22 million to settle parallel civil and criminal proceedings involving...more