Events
Beneficial ownership remains a compliance hot topic. While understanding beneficial ownership of an entity - a corporate or fund - is a key element in many compliance activities, it's a daunting challenge. Countries vary in the amount of financial data private companies are required to disclose, and disclosure of ownership
General
The term “due diligence” is an overused expression in the compliance world. It has become a term to mean heightened concern or investigation. No one can really define what it means except to say it has different meanings in different contexts. Some would say it is a term of art
General
Analogic Corp. and its Danish subsidiary, BK Medical ApS, settled an FCPA enforcement action last week with the Justice Department and the SEC for approximately $14 million. Analogic agreed to pay $3.4 million to the Justice Department as part of a non-prosecution agreement (NPA), and paid the SEC
General
In case you are not following all the latest scandals – Unaoil and the Panama Papers being two significant ones – we are seeing an evolution and possibly a revolution in due diligence expectations. No matter what context or what your specific concern may be, the need for every compliance department to
General
Since 2010, the Justice Department and the SEC have been “investigating” a number of private equity and hedge funds for FCPA violations. The launch of the inquiries was a big deal with lots of fanfare and focus on private equity corruption risks. In time, nothing happened. Well, that is about
General
Welcome back to the Department of Justice and FCPA enforcement. After a lengthy hiatus, DOJ returned to the FCPA enforcement scene with a demonstration of its full capability, assuming certain individuals are prosecuted criminally out of the case. (I know technically they reappeared with the PTC non-prosecution agreement but