FCPA and AML Enforcement Review—"Follow the Money:" Liberty Case Review

By: Jacqueline C. Wolff | John F. Libby
– Payments Compliance

This month we highlight three recent instances where the federal enforcement agencies have announced settlements, prosecutions and orders in their continued efforts to "follow the money" down the twin rabbit holes of bribes payments and money laundering. The SEC announced settlements in three Foreign Corrupt Practices Act cases in the first week of February 2016 while the DOJ successfully prosecuted the founder of Liberty Reserve, a now defunct virtual currency service that was allegedly "once used by cybercriminals around the world to launder the proceeds of their illegal activity." In addition, the Treasury Department's Financial Crimes Enforcement Network issued "Geographic Targeting Orders" aimed at uncovering the identities of individuals who launder money through shell companies via all-cash high-end residential real estate deals in New York and Florida. Read on for a recap.

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