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As we saw in Part One, regulators have recently shown a tendency to focus on compliance officers who they deem to have failed to ensure that the compliance and anti-money laundering (AML) programs that they oversee adequately prevented corporate wrongdoing, and there are several indications that regulators will continue to target compliance officers in 2018 in actions focused on Bank Secrecy Act/AML compliance.
As we saw in Part One in last month’s newsletter, regulators have recently shown a tendency to focus on compliance officers who they deem to have failed to ensure that the compliance and anti-money laundering (AML) programs that they oversee adequately prevented corporate wrongdoing, and there are several indications that regulators will continue to target compliance officers in 2018 in actions focused on Bank Secrecy Act (BSA)/AML compliance.
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Questions Surround Expanded Government Authority to Seize Russian Assets
By Robert J. Anello and Richard F. Albert
The purpose behind the Biden Administration's proposals to seize assets of Russian oligarchs is to punish a specific action by a state actor — Russia’s invasion of Ukraine. The proposals, however, do not appear to be limited to this conduct alone and would outlast Russia’s invasion. In times of war, it at least arguably may be appropriate to pass laws to expand the executive’s authority to address specific hostile conduct. Such laws, however, should end with the conflict.
The FRCP Rule 9(b) Standard In False Claims Act Cases
By Michael A. Sirignano
In recent years, federal circuit courts of appeals have set forth somewhat different standards that civil FCA complaints brought by private citizens, known as relators, must meet to satisfy Rule 9(b) — especially regarding whether representative examples of allegedly fraudulent claims must be included in a complaint.
By G. Zachary Terwilliger
Consider another paradox of the post-COVID world: The pandemic that initially disrupted federal prosecution of corporations has now heightened potential exposure in a number of areas. This is especially the case for those organizations that took advantage of government aid or today struggle to navigate snarled global supply chains.
Climate Change Risk and Disclosure: A New Focus for SEC Enforcement
By Jacqueline C. Wolff
Given the massive amount of dollars being poured into ESG funds and the SEC’s renewed focus on both the funds and the companies in the funds, there is no time like the present for companies to engage in an assessment of their climate risks and how these risks and the status of the companies’ ESG goals are being relayed to investors.
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