Destigmatizing the Practice of Whistleblowing
In the wake of the financial crisis of 2008, the Dodd-Frank Act (“Dodd-Frank”) was signed into federal law on July 21, 2010. At the time, the recession was considered the worst financial crisis since the Great Depression. It seemed like a 100-year storm. As it turns out, it was only a 12-year storm. The passage…
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The Achilles Heel of FCPA Compliance: Bribe-paying Intermediaries
According to Stanford University Law School’s Foreign Corrupt Practices Act Clearinghouse, between 2001 and 2019, there were 268 FCPA enforcement actions. 246 (or 91.7%) of the bribes were paid by third parties as opposed to officers or employees of the defendant company. Sales agents, distributors, JV partners, resellers, freight forwarders, customs brokers, lawyers and accountants…
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Chasing Bernie’s Billions: Inside the Most Successful Asset Recovery Effort in History
On December 11th, 2008 Bernie Madoff was arrested by the FBI in his Manhattan home and criminally charged with a multi-million-dollar securities fraud scheme. So began the most comprehensive and successful financial investigation and asset search in history. The Securities Investor Protection Corporation (“SIPC”) Trustee and Baker Hostetler have continued their tireless search for assets…
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Keeping Dirty Money Offshore: Corporate Transparency Act Makes U.S. Less of a Safe Haven
On April 3rd, 2016, information about 214,488 offshore companies established by Panamanian law firm Mossack Fonseca leaked. The leak comprised over 11 million documents and 2.6 TB of data and opened a rare glimpse into how the wealthy and powerful shelter their income and conceal their wealth. Named in the leak were 12 current or…
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From Systemically Corrupt to Above Reproach: Examining Siemens’ Remarkable Turnaround
Peter Solmssen was brought into Siemens to accomplish the impossible – upend the morally bankrupt, corrupt culture of Siemens that was systematically paying bribes in every corner of the world and transform it into a model of compliance reform and ethical culture. Peter and former SEC FCPA Unit Chief Kara Brockmeyer joined me to discuss…
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Did Your New Refrigerator Help Fund Terrorism? Trade-Based Money Laundering Exploits Demand for Consumer Goods
Of the three primary methods that transnational criminal and terrorist organizations utilize to launder the proceeds of illicit activity and finance terrorism, trade-based money laundering is arguably the most challenging. Most people associate money laundering with the misuse of financial institutions or the bulk movement of hard currency using smuggling techniques, but trade-based money laundering…
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The Interrelationship Between Major Investigations and Crisis Communications
In 2020 and continuing into 2021, the term crisis communications seems almost redundant. We are bombarded every day with information about the pandemic death toll and infection rates, the largest cyber-attack in history, the financial crisis, efforts to overturn a presidential election and an attack on the US Capitol building while Congress was in session.…
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Derisking and Outdated CTR Thresholds: AMLA 2020 Seeks to Address Persistent AML Challenges
The Anti-Money Laundering Act of 2020 is the most comprehensive set of reforms to U.S. anti-money laundering laws since the passage of the USA PATRIOT Act in 2001. The Act contains some important changes and enhancements that should have an immediate and long-lasting impact on anti-money laundering. Gibson Dunn litigation partner and anti-money laundering expert…
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Thwarting Mobsters, Drug Lords and Terrorists – Anti-Money Laundering Continues to Adapt
The Anti Money Laundering Act of 2020 (AMLA 2020) is the most comprehensive set of reforms to US anti-money laundering laws since the passage of the USA PATRIOT Act in 2001. The Act has some important changes and enhancements that should have an immediate and long-lasting impact on anti-money laundering. I recently spoke to anti-money…
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The Strange Bedfellows of Cyber Defense
Cybersecurity risks seem to be expanding exponentially. Business Email Compromise schemes are among the fastest-growing financial crimes. Ransomware attacks are crippling hospital systems, disrupting manufacturing and retail operations and supply chains and threatening our critical infrastructure. Personal identifying information is being harvested millions of records at a time from credit bureaus, government agencies, financial services…
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Fraud Eats Strategy 