Mincey & Bell to Present to Swedish and Danish Lawyers About International Money Laundering Investigations

Patrick Mincey and Stephen Bell will present on the Anti-Money Laundering Improvement Act and the U.S. Department of Justice’s recently announced criminal whistleblower program to an audience of Swedish and Danish lawyers at the JUC Institute on April 12. JUC Institute was founded in Denmark in 2001 and today offers continued legal education for attorneys there and across Sweden, […]

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U.S. Whistleblower Program Expands

U.S. Whistleblower Program Expands to Allow the Payment of Awards to Non-U.S. Citizens, Auditors, and Compliance Professionals Who Report Financial Crimes or Money Laundering Article co-written by Stephen Bell, Patrick Mincey, and Silvia Palomba of Arděnter Law In December 2022, the U.S. Congress included the Anti-Money Laundering Whistleblower Improvement Act as part of the Omnibus […]

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FinCEN Issues Updated Geographic Targeting Order Expanding the List of High-Risk Jurisdictions in Which Title Insurers Must Report the Ultimate Beneficial Ownership of Entities Purchasing Residential Real Estate

The Financial Crimes Enforcement Network (“FinCEN”) is statutorily entitled to impose recordkeeping and reporting requirements on domestic financial institutions or nonfinancial trades or business groups when it deems such regulation necessary to carry out the purposes of the Bank Secrecy Act. See 31 U.S.C. § 5326(a); 31 C.F.R. § 1010.370; Treasury Order 180-01. This includes […]

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SEC Charges Binance and Coinbase in Latest Efforts to Crack Down on Crypto Industry

The cryptocurrency industry has been under regular fire from regulators this year. The latest companies to face the wrath of the federal government are also some of the largest. Earlier this month the Securities and Exchange Commission (“SEC”) brought charges against Binance (and its founder, Changpeng Zhao) and Coinbase – both household names known by […]

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DOJ Announces Sweeping Voluntary Corporate Self-Disclosure Policy

In late February, the United States Attorneys for the Southern and Eastern Districts of New York announced a new “Voluntary Self-Disclosure Policy” (VSD Policy), effective immediately, that applies to all United States Attorney’s Offices (USAOs).  A result of the “Monaco Memo” – a September 15, 2022 memorandum titled “Further Revisions to Corporate Criminal Enforcement Policies […]

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Congress Dramatically Expands Whistleblower Eligibility to Include Auditors & Compliance Professionals to Combat Kleptocratic Money Laundering in Global Financial System, With New Sweeping Financial Incentives

On December 23, 2022, Congress included the Anti-Money Laundering Whistleblower Improvement Act as part of the Omnibus Budget President Biden has now signed into law.  The Act includes drastic new measures to expand enforcement against kleptocratic money launderers operating in the United States financial system and abroad, chiefly by expanding the incentives for whistleblowers with […]

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Behind the scenes of how Trump’s Truth Social was born, and how it could fall apart

Former President Donald Trump and Miami financier Patrick Orlando celebrate their companies’ merger to create Truth Social at Mar-a-Lago. Courtesy of William Wilkerson and attorneys. Former President Donald Trump’s quest to establish a Florida-based social media platform as a conservative alternative to Twitter will face a critical vote on Monday when investors decide whether to […]

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DOJ Announces Revisions to Corporate Criminal Enforcement Policies

Earlier this month, DOJ announced additional revisions to the Department’s existing policies and practices governing corporate criminal enforcement. Each of these revisions will soon find its way into DOJ’s Justice Manual. Here are the most important takeaways: Guidance on Individual Accountability. DOJ’s top priority in prosecuting corporate criminal matters is to deter future bad acts […]

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DOJ Announces Early Targets of Task Force KleptoCapture, Elite Anti-Money Laundering Initiative Established to Halt Russian Oligarchs and their Co-Conspirators in the International “Invisible Economy”

In late May, a court in the Pacific island nation of Fiji upheld on appeal the detention of the 348-foot Amadea, reportedly owned by Russian oligarch Suleiman Kerimov, whose wealth largely derives from his 76% stake in Russia’s biggest gold producer, Polyus.  The United States Treasury sanctioned Kerimov in 2018 for alleged money laundering related to the purchase of French […]

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Evolving DOJ Enforcement Trends: Considerations for White Collar Practitioners and Their Clients

In September 2020, Patrick Mincey and I presented on the changes and trends we expected to see in SEC and DOJ enforcement of white-collar cases.  We cautioned our clients that the government was going to shift its focus and efforts towards C-suite executives, corporate gatekeepers and inadequate or poorly-designed corporate compliance programs.  While our clients’ investigative matters and reported […]

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