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Update on the Proposed Amendments to the Foreign Agents Registration Act Regulations
On her very first day in office, Attorney General Pam Bondi issued a sweeping memorandum laying out what the Department of Justice’s (DOJ) enforcement priorities will be going forward under her leadership. It seems that the Foreign Agents Registration Act (FARA) will not be among those priorities, or, at least, the focus of FARA criminal…
UK Sanctions Update: New OFSI Reporting Requirements for High Value Dealers and Art Market Participants
Late in 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), the agency within His Majesty’s Treasury that is charged with the implementation of financial sanctions in the UK, introduced new sanction measures aimed generally at augmenting the operation and enforcement of UK financial sanctions and targeted specifically at High Value Dealers (“HVDs”) and Art…
To Disclose or Not to Disclose (and how much) – That is the Question
The decision-making process involved in disclosing a cyber incident is a nuanced and delicate dance. Companies need to consider a myriad of factors, including when to disclose and how much detail to disclose to employees, customers, or regulators, such as the Securities and Exchange Commission (“SEC”).
A New York bank was recently forced to pay…
DOGE and a New Senate Caucus May Further Empower Inspectors General
In the flurry of developments last week in the run-up to the inauguration, it was easy to overlook one that could have significant and positive impact by making government more effective, efficient, and economical.
On January 17, 2025, Senators Joni Ernst (R-IA) and Chuck Grassley (R-IA) announced the launch of a bipartisan Inspector General Caucus.…
Time is of the Essence to Implement New ADGM Whistleblower Protection Regulations
In 2024, the Abu Dhabi Global Market (“ADGM”) further enhanced transparency, accountability, and market integrity within the financial freezone by introducing the Whistleblower Protection Regulations 2024 (the “Regulations”). In brief, those Regulations require certain entities registered or licensed to operate or conduct any activity within the ADGM to implement arrangements for handling whistleblowing, including having…
Promising Results from Groundbreaking FinCrime Data Sharing Project Between Seven UK Banks and the National Crime Agency
In 2024, the National Crime Agency (the “NCA”), which is the UK’s lead agency against organized crime; human, weapon and drug trafficking; cybercrime; and economic crime, announced its “groundbreaking” data sharing partnership with seven UK banks, namely Barclays, Lloyds, Metro Bank, NatWest, Santander, Starling Bank, and TSB.[1]
This new public-private partnership (“PPP”) was the…
EU Strengthens Sanctions Against Russia with 15th Package of Restrictive Measures
On December 16, 2024, the European Union (EU) adopted its 15th package of sanctions against Russia in response to its ongoing aggression toward Ukraine. The new measures target key sectors of Russia’s military-industrial complex, including the “shadow fleet” and companies that support this complex. Our colleagues at The Trade Practitioner cover this significant development in…
OFAC Issues Additional Sanctions Guidance for the Maritime Shipping Industry
Failure to comply with the complex web of US sanctions laws and regulations carries significant risks both in terms of exposure to civil fines and penalties and reputational harm. To help maritime sector stakeholders navigate these regulations, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) has published scenario-based sanctions compliance guidance on…
France Issues Further CSRD Guidance on Compliance Reporting
Our colleagues Marion Seranne and Saeid Abedi recently covered the French Anti-Corruption Agency’s (“AFA”) newly published guidance addressing Corporate Reporting Sustainability Directive (“CSRD”) reporting for companies that do not meet the French Sapin II law thresholds. In short, the agency stated that CSRD reporting standards trigger an obligation to implement an antibribery and corruption compliance…