The Treasury Department’s Financial Crimes Enforcement Network issued new rules Wednesday to force U.S. title insurance companies to identify the natural persons behind companies used to pay all cash for high-end residential real estate in the Borough of Manhattan in New York City and in Miami-Dade County, Florida.… Continue Reading
The DOJ and SEC haven’t used the word “scalable” to describe an effective compliance program. But they’ve described scalability when talking about what’s needed.
For example, part of the job of the DOJ’s new compliance counsel is to help “assess a company’s program, as well as test the validity of its claims about its program, such as whether the compliance program truly is thoughtfully designed and sufficiently resourced to address the company’s compliance risks.”… Continue Reading
After reading my earlier posts about privatization opportunities in Kazakhstan and the deterrent effect of the FCPA on American investment in that country, and Kazakh listings in the U.S., a reader asked whether it is difficult to do business in Kazakhstan in an FCPA-compliant manner.… Continue Reading