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White Collar Crimes FinCEN Compliance

Herbert Smith Freehills Kramer

US Corporate Governance — 2025 Midyear Review

The Financial Crimes Enforcement Network (FinCEN) issued an interim final rule in March 2025 that removes requirements for US companies to report beneficial ownership information under the Corporate Transparency Act (CTA)....more

Tonkon Torp LLP

Oregon HOAs Should Continue to Prepare for Compliance with Corporate Transparency Act

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The Corporate Transparency Act (CTA), enacted to combat financial crimes, requires certain entities to report beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN). While legal challenges...more

A&O Shearman

Whistleblowing: ensure programs are fit for 2025

A&O Shearman on

Whistleblowing has become an increasingly critical aspect of corporate governance and compliance, especially for multinational companies operating across diverse legal and regulatory landscapes. We see increased efforts by...more

Holland & Knight LLP

Ringing the (Jingle) Bell: Whistleblower Program 2024 Recap

Holland & Knight LLP on

Whistleblower programs are the gifts that keep giving to enforcement agencies, driving a record number of cases, sanctions and awards across multiple agencies. In this ninth installment of Season's Readings, we revisit some...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 5- The Reckoning

Today, I want to review the OCC Consent Order to see the bank’s requirements. This is separate from the DOJ requirements under the Bank’s Plea Agreement(s) and the FinCEN Consent. Further, the DOJ and OCC have mandated...more

The Volkov Law Group

TD Bank’s Rotten Corporate Culture — From its Store-Level Operations to its Board’s Audit Committee (Part IV of IV)

The Volkov Law Group on

TD Banks’ complete compliance disaster was reflected in every aspect of TD Bank’s business and compliance operations. It is not surprising that TD Bank’s deficient BSA and AML compliance program was known by its Board of...more

The Volkov Law Group

TD Bank’s $3 Billion Settlement: A Review of Regulatory Settlements  (Part III of IV)

The Volkov Law Group on

TD Bank’s $3 billion settlement included coordinated regulatory settlements with the Federal Reserve Board (“Federal Reserve”), The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), and the...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 2 – When Profits Trump Compliance: A Recipe for Corporate Disaster

We continue our exploration of the resolution of the AML/BSA enforcement action involving TD Bank US (the Bank), which is wholly owned by TD Bank Group, a publicly traded (NYSE: TD) international banking and financial...more

The Volkov Law Group

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV)

The Volkov Law Group on

In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 1-Money Laundering and the China Syndrome

Last week, representatives of the US government announced one of the largest sets of fines and penalties for failures in anti-money laundering ever laid down. It involved TD Bank N.A. and TD Bank US Holding Company. It was...more

White & Case LLP

DOJ Launches New Whistleblower Pilot Program

White & Case LLP on

In March 2024, we published an alert regarding Deputy Attorney General (“DAG”) Lisa Monaco’s announcement that the US Department of Justice (“DOJ” or the “Department”) intended to design and implement a new whistleblower...more

BakerHostetler

DOJ Corporate Whistleblower Awards Pilot Program

BakerHostetler on

DOJ has introduced the new three-year Pilot Program, managed by the Criminal Division’s Money Laundering and Asset Recovery Section, effective August 1. Under this Pilot Program, whistleblowers meeting certain criteria may be...more

Dorsey & Whitney LLP

DOJ’s New Whistleblower Program Incentivizes Individuals and Corporations to Disclose Wrongdoing

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The U.S. Department of Justice (DOJ) just launched the new corporate whistleblower awards pilot program that it previewed this past March. ...more

BCLP

DOJ Piles On the Incentives for Individuals to Blow the Whistle on Companies

BCLP on

Historically, successful white-collar prosecutions often turn on the government’s ability to identify “insiders” with firsthand knowledge of the alleged criminal scheme, who opt to cooperate with prosecutors in exchange for...more

Latham & Watkins LLP

DOJ Launches New Whistleblower Incentive Program

Latham & Watkins LLP on

DOJ’s pilot program aims to fill gaps in existing federal whistleblower programs and incentivize prompt corporate self-disclosure alongside individual whistleblower tips. Following the March 2024 announcement of its...more

The Volkov Law Group

FinCEN Issues Proposed Rule to Strengthen and Modernize Financial Institutions’ AML/CFT Programs

The Volkov Law Group on

On June 28, 2024, the Financial Crimes Enforcement Network released a notice of proposed rulemaking. The purpose of the proposed rule is to strengthen and modernize Anti-Money Laundering and Countering the Financing of...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Launches Corporate Whistleblower Awards Pilot Program and Announces a New Incentive for Self-Reports

On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more

NAVEX

The Broader Significance of the DOJ Whistleblower Rewards Program

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The Department of Justice (DOJ) signaled it will soon join the list of government agencies to have implemented a whistleblower rewards program, putting further pressure on companies to have in place an effective compliance...more

Jenner & Block

Client Alert: DOJ Announces New Whistleblower Rewards Program and Enhanced Focus on AI-Related Risks

Jenner & Block on

Continuing to prioritize corporate criminal enforcement, the Department of Justice (DOJ) announced two new steps it is taking to identify potential corporate misconduct and evaluate companies’ compliance programs. Deputy...more

Dorsey & Whitney LLP

DOJ to Develop New Whistleblower Program to Augment Existing Federal Whistleblower Programs

Dorsey & Whitney LLP on

Last week Deputy Attorney General Lisa Monaco announced that the U.S. Department of Justice (DOJ) will soon begin a pilot program to reward whistleblowers who alert prosecutors to significant corporate misconduct. The goal of...more

ArentFox Schiff

Investigations Newsletter: Deputy Attorney General Monaco Warns Industries: “Fraud Using AI is Still Fraud”

ArentFox Schiff on

On March 7, Deputy Attorney General Lisa Monaco delivered the keynote remarks at the American Bar Association’s (ABA) 39th National Institute on White Collar Crime. She noted that artificial intelligence (AI) “holds great...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOJ Official Cites Old West ‘WANTED’ Posters in Announcement of New Whistleblower Monetary Awards Program

On March 7, 2024, Deputy Attorney General Lisa Monaco said that the U.S. Department of Justice (DOJ) will test out a program to pay whistleblowers if they provide information on serious financial crimes and foreign and...more

Womble Bond Dickinson

DOJ Announces New Policies on AI Compliance and a Pilot Whistleblower Rewards Program

Womble Bond Dickinson on

Last week, senior Department of Justice leadership announced new policies and programs intended to further its “carrot and sticks” approach to corporate criminal enforcement, which has borne fruit with twice as many voluntary...more

American Conference Institute (ACI)

Navigating U.S. Sanctions and Export Control Restrictions

Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more

The Volkov Law Group

FinCEN Issues Final Rule for Beneficial Ownership Reporting

The Volkov Law Group on

The Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued its final rules implementing the beneficial ownership reporting requirements pursuant to the bipartisan Corporate Transparency Act (“CTA”).  The...more

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