On June 9, Deputy Attorney General Todd Blanche issued a memorandum entitled Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (the Memo) addressed to the head of the Criminal Division of the U.S. Department of Justice (DOJ) laying out the evaluation criteria and a non-exhaustive list of factors the Criminal Division should use to decide whether to pursue a Foreign Corrupt Practices Act (FCPA) case. The FCPA is the primary law by which the U.S. government seeks to prosecute and penalize bribery of non-U.S. government officials.Continue Reading Is the “Pause” Over? DOJ Resumes FCPA Enforcement, Announces Guidelines
Anti-Money Laundering
Anti-Money Laundering Update: California Card Club Clubbed by FinCEN for AML Violations
By Thad McBride on
Posted in Anti-Money Laundering, Compliance
Post at a glance:
- FinCEN imposes $8 million penalty against California’s biggest and oldest card club
- Club failed to implement and maintain an effective anti-money laundering (AML) program and failed to detect, deter, and report suspicious transactions
- Enforcement action serves as valuable reminder of scope of Bank Secrecy Act (BSA)
As mentioned in our prior AML Update, the U.S. Financial Crimes Enforcement Network (FinCEN) continues to aggressively enforce anti-money laundering and other financial crimes laws.
The latest target? California’s biggest and oldest card club, Artichoke Joe’s.Continue Reading Anti-Money Laundering Update: California Card Club Clubbed by FinCEN for AML Violations