Posts Tagged With Compliance

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Assistant Attorney General Leslie R. Caldwell Speaks at Treasury Roundtable on Financial Access for Money Service Businesses

On January 13, Leslie R. Caldwell, the Assistant Attorney General for the Criminal Division, spoke about DOJ’s prosecutions of money services businesses.  Ms. Caldwell focused on the prosecutions of MoneyGram and Belair Payroll Services Inc.  Ms. Caldwell said that the keys for financial institutions providing services to money services businesses (and other potentially high-risk clients) are to:  (1) “know your customer”; (2) understand the risks that a particular customer presents; (3) have an AML
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Chief Compliance Officer Sentenced for Fraud Scheme Worth Hundreds of Millions of Dollars

On January 8, Deborah Duffy, the former Chief Compliance Officer of WG Trading Company, LP (“WG Trading”), was sentenced in the Southern District of New York to time served after pleading guilty to conspiracy, securities fraud, and money laundering on July 21, 2009.  Duffy was also ordered to forfeit $1,272,841 and pay a restitution amount to be determined.  According to the government, Duffy maintained the books and records for WG Trading, a fraudulent commodities trading
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Alstom Pleads Guilty and Agrees to Pay $772 Million Criminal Penalty to Resolve Foreign Bribery Charges

On December 22, Alstom S.A., a French power and transportation company, pleaded guilty in the District of Connecticut and agreed to pay a $772,290,000 fine to resolve charges related to a widespread scheme involving tens of millions of dollars in bribes in connection with power and transportation projects for state-owned entities around the world, including in Indonesia, Egypt, Saudi Arabia, the Bahamas and Taiwan.  In Indonesia, for example, Alstom-related entities paid bribes to government officials
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United States Brings Civil Enforcement Action Against Former Chief Compliance Officer of Moneygram International, Inc. for Violating the Bank Secrecy Act

On December 9, the United States filed a civil enforcement action in the Southern District of New York against Thomas E. Haider, the former Chief Compliance Officer of MoneyGram International, Inc., for violating the Bank Secrecy Act (“BSA”).  The Complaint alleges that, notwithstanding his obligations as MoneyGram’s Chief Compliance Officer, Haider violated the BSA by failing to ensure that MoneyGram: (1) implemented and maintained an effective anti-money laundering program; and (2) filed timely suspicious activity
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Avon China Pleads Guilty to Violating the FCPA by Concealing More Than $8 Million in Gifts to Chinese Officials

On December 17, Avon Products (China) Co. Ltd. (Avon China), a wholly owned subsidiary of the New York-based cosmetics company Avon Products Inc. (Avon), pleaded guilty in the Southern District of New York to conspiring to violate the accounting provisions of the FCPA to conceal more than $8 million in gifts, cash and non-business meals, travel and entertainment it gave to Chinese government officials in order to obtain and retain business benefits for Avon China. 
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Bank of America Agrees to Pay $16.65 Billion in Settlement

On August 21, DOJ announced that it had reached a $16.65 billion civil settlement with Bank of America  to resolve federal and state claims against Bank of America and its former and current subsidiaries, including Countrywide Financial Corporation and Merrill Lynch.  As part of the settlement, the Bank  acknowledged that it sold billions of dollars’ worth of residential mortgage-backed securities (RMBS) without disclosing to investors key facts about the quality of the securitized loans.  The
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Hewlett-Packard Co. Resolves FCPA Bribery Charges

On April 9, 2014, Hewlett-Packard Co. (“HP”) and related entities resolved an FCPA investigation by the DOJ and SEC for separate conduct in Russia, Poland and Mexico.  HP’s Russian subsidiary pled guilty to anti-bribery, internal controls, and books and records violations and conspiracy for improper payments to Russian government officials.  Participants in the scheme created an off-the-books slush fund by inserting intermediaries in a deal to modernize the telecommunications and computing infrastructure of a Russian
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Toyota Enters Into DPA, Agrees to Pay $1.2 Billion to Resolve Wire Fraud Allegations

On March 19, Attorney General Eric Holder and other government officials announced a deferred prosecution agreement (“DPA”) with Toyota Motor Corporation (“Toyota”) to resolve allegations that Toyota issued misleading statements about safety issues in Toyota and Lexus vehicles in fall 2009 and early 2010.  The DPA requires Toyota to pay a $1.2 billion civil financial penalty and imposes an independent monitor to review and assess Toyota’s policies, practices and procedures relating to Toyota’s safety-related public
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