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FCPA Liability For Hiring Practices Gains New Credence

By Bruce L. Udolf, P.A. |

The U.S. Department of Justice and the U.S. Securities and Exchange Commission have stood by an expansive theory of anti-bribery liability under the Foreign Corrupt Practices Act for corrupt hiring schemes. Even as some still questioned the commitment of the Trump administration to enforcement of the FCPA, publicly traded Credit Suisse AG and its… Read More »

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The FCPA Corporate Enforcement Policy in Action-Part I

By Bruce L. Udolf, P.A. |

We had three major Foreign Corrupt Practices Act (FCPA) cases resolved in Q2 2018. They all reached different resolutions under the new FCPA Corporate Enforcement Policy and the new anti-piling on policy. I thought it might be interesting to review the matters and consider what differences led to the results under the new Department… Read More »

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The FCPA Corporate Enforcement Policy in Action-Part II

By Bruce L. Udolf, P.A. |

How should a compliance practitioner use the information from these three Foreign Corrupt Practices Act (FCPA) enforcement actions going forward? Do the differing results in these three enforcement actions (Dun & Bradstreet [D&B], Panasonic Avionics [PAC] and Credit Suisse [CSAG] & [CSHK]) assist a company in incentivizing self-disclosure? Do they even come into the… Read More »

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Congressman: ‘Prohibit US Persons From Buying Or Mining Cryptocurrencies’; Crypto World Erupts

By Bruce L. Udolf, P.A. |

In his opening remarks at the Subcommittee on Monetary Policy and Trade (Committee on Financial Services) Hearing: ‘The Future of Money: Digital Currency’ on July 18, 2018, Congressman Brad Sherman (D-CA) called for the prohibition of both buying and mining cryptocurrencies (crypto) for all US citizens. With this statement, he turned over the cryptocurrency… Read More »

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Crypto Crime In 2018 By The Numbers

By Bruce L. Udolf, P.A. |

One of cryptocurrency’s biggest selling points up to this point has been its anonymous nature, but that anonymity has given cryptos a bit of a nefarious reputation. While the cryptocurrency market has been subject to a wave of new regulations in 2018, a new report from CipherTrace indicates cryptocurrency-related criminal activity has exploded as… Read More »

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IRS-CI Joins International Effort To Fight Tax, Cryptocurrency And Financial Crimes

By Bruce L. Udolf, P.A. |

Realizing that more work is needed to combat global crimes, leaders of tax enforcement authorities from five nations announced that they have created a united operational alliance, the Joint Chiefs of Global Tax Enforcement, known as the J5. The J5 consists of criminal intelligence communities from Australia, Canada, the Netherlands, the United Kingdom and… Read More »

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Those threatening scam IRS phone calls? Somebody’s going to jail for them

By Bruce L. Udolf, P.A. |

A Davie woman was convicted last week for her part in an IRS phone call scam, a popular con game over the past few years that tries to sucker people into sending money to scammers. Amy Ahrens wasn’t the phone voice that claims to be from the IRS and threatening the person being called… Read More »

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Crypto Crime Is a Focus of Trump’s New Task Force on Consumer Fraud

By Bruce L. Udolf, P.A. |

In forming a new task force to protect consumers from fraud, the Trump administration made clear that one of the greatest threats to the public is just emerging: red-hot markets for crypto coins. The inclusion of virtual tokens — along with traditional crimes like money laundering and investment schemes targeting the elderly — as… Read More »

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IRS Teams Up With Other Nations To Attack Cryptocurrency Tax Crimes

By Bruce L. Udolf, P.A. |

The IRS and four other countries have created a task force to investigate cryptocurrency crime, including tax fraud and money laundering. U.S. tax authorities will work with those from Australia, Canada, the U.K. and the Netherlands to counter “the growing threat” from cryptocurrencies. Known as the Joint Chiefs of Tax Enforcement, or J5, the… Read More »

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The Morning Risk Report: C-Suite on Hot Seat Over Bribery, Study Says

By Bruce L. Udolf, P.A. |

Senior executives are in the cross-hairs as the U.S. continues to crack down on individuals in corporate bribery cases, according to research published this week by a law firm. More than half of the people charged with violating the nation’s foreign-bribery law in the past 13 years worked near the top of the corporate… Read More »

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