The Compliance Kitchen returns with a wrap-up of the week’s top trade and economic sanction issues. In today’s episode, Silvia Surman looks at the EU prolonging economic sanctions over Russia’s military aggression against Ukraine; FinCEN designates virtual currency exchange Bitzlato a “Primary Money Laundering Concern” for illicit Russian finance; DOJ obtains guilty plea from a military contractor for rigging bids on government military contracts.
Tag: FinCen
In this episode of the FCPA Compliance Report, I am joined by Mary Inman, partner at Constatine Cannon. We look at recent developments in whistleblowing and how the Ukraine War has increased the visibility of whistleblowers. Highlights of this podcast include:
- Whistleblower Reward Program at the US Treasury Department/FinCEN – what is its relevance to corruption, anti-money laundering and the Ukraine conflict.
- The House Committee on Financial Services voted to strengthen the U.S. Treasury’s Anti-Money Laundering (AML) whistleblower program. What does this mean for this nascent program?
- How does a minimum whistleblower reward threshold, whistleblower incentives and injects more certainty into the Anti-Money Laundering whistleblower program.
- How does expanding AML whistleblower rewards to cover laws applicable to Russian sanctions, Congress is enlisting the help of the private citizenry.
- Lisa Monaco recently spoke about the government relying on corporations to ID instancesof money-laundering and other activities to help enforcement Russia economic sanctions and broader trade sanctions. Do you see private citizen or other whistleblowers as a key component of this fight?
- How has the Ukraine War raised the profile of whistleblowers and whistleblowing?
- Starting with SOX, then Dodd-Frank and the AML Law of 2020 has the US government began to understand whistleblowers as a key component in the fight against fraud, waste and abuse.
- Has the government embraced these same strategies and tactics in the wider fight against corruption?
- Tribute to Chuck Grassley for his advocacy of whistleblowers.
Resources
Mary Inman on Constantine Cannon website
Categories
SAR Filing Trend from 2021
2021 SAR Filing Trend Data Now Available on FinCEN’s Website.
Categories
FinCEN Solicits Comments
The Kitchen discusses the opening of FinCEN Public Comment window on sharing of SARs.
FinCEN announced CommunityBank of Texas, N.A. penalty for Bank Secrecy Act violations.
FinCEN opens public comment window: how to modernize the U.S. AML/CFT regulatory regime.
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom begin a special two-part podcast series of several topics they will be following in 2022. Today in Part 1, we consider
- The Biden Administration’s Strategy on Countering Corruption, specifically around FinCEN and AML enforcement and how it may impact FCPA enforcement.
- The PCAOB was long dysfunctional before the Trump Administration eviscerated it. How will it change under the Biden Administration?
- The SEC plans for the regulation of and reporting on ESG.
- FCPA enforcement for recidivist corporations after DAG Lisa Monaco’s speech in October 2021.
Resources
Matt in Radical Compliance
FinCEN publishes a Notice on environmental crimes and related illicit financial activity. Drop by for a quick review.
Categories
FinCEN Update
FinCEN issued an updated “Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments”. Tune in for more details as the Kitchen reviews this latest resource.
