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On October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security ("BIS") issued critical guidance aimed at enhancing financial institutions’ compliance with the Export Administration Regulations ("EAR"). This development comes at a time when financial institutions are increasingly becoming focal points
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The SEC notched another FCPA settlement, continuing its steady pursuit and resolution of FCPA cases. In the meantime, the Justice Department has been silent in the FCPA enforcement arena. In its latest settlement, Moog, Inc. ("Moog"), a New York-based global manufacturer of motion controls systems for aerospace,
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October 29, 2024 11 AM EST Sign Up Here Global companies are being challenged with rapidly expanding third-party risks. Cybersecurity, data privacy, and new technologies, such as artificial intelligence, are exponentially expanding third-party risks. The traditional constellation of legal and compliance now includes technology risks that require compliance
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The Justice Department's Antitrust Division has been aggressively pursuing civil enforcement actions. While criminal enforcement of antitrust laws has been depressed, DOJ has found success in pursuing civil and merger enforcement. DOJ recently won a significant victory against Google for its monopolization of the search market. DOJ has
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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 Directors and senior leadership. TD Bank's priority
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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 Office of the Comptroller of the Currency ("OCC"). Each regulator imposed
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“By making its services convenient for criminals, TD Bank became one,” Attorney General Merrick B. Garland. TD Bank joins the list of dysfunctional companies -- add them to Wells Fargo, Wirecard, Volkswagen, General Motors, Goldman Sachs, and the hall of fame of financial scandals. TD Bank became a criminal organization, its
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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 settlement with TD Bank companies to resolve systemic and pervasive Bank Secrecy Act ("BSA") and
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The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs. As everyone knows, the Justice Department's guidance carries talismanic significance -- it is an important document that provides important direction on the design and implementation of an effective compliance program. DOJ understands the importance of
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In late August 2024, the UK's Office of Financial Sanctions Implementation ("OFSI"), a department within HM Treasury, imposed a monetary penalty of £15,000 on Integral Concierge Services Limited ("ICSL")—a UK-based property management and concierge company—for serial breaches of the Russia
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On September 30, 2024, Quantum Corporation—a U.S.-based technology company— reached a settlement with the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") to resolve 45 separate violations of the antiboycott provisions of the Export Administration Regulations (“EAR”). The antiboycott provisions
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The Justice Department's Antitrust Division has been aggressively pursuing civil enforcement actions. While criminal enforcement of antitrust laws has been depressed, DOJ has found success in pursuing civil and merger enforcement. DOJ recently won a significant victory against Google for its monopolization of the search market. DOJ has