In part 1 of this Fraud Eats Strategy series, we discuss how to bring order to the chaos of the early days of an FCPA investigation and avoid mortgaging the company’s future in the process. For more information visit FraudEatsStrategy.com ..read more

In part 2 of this series, we continue to discuss the tools that cybersecurity teams use to combat ransomware attacks. For more information visit FraudEatsStrategy.com ..read more

Ransomware is a type of malware used by criminal organizations to gain unlawful access to computer networks and encrypt the data stored on those networks and render it unusable. The criminal organization then holds the data hostage until a ransom payment is made. If the ransom is not paid, the victim organization’s data will either remain encrypted and unusable or it could be released to the public.  For more information visit FraudEatsStrategy.com ..read more

Monitorships, transaction lookbacks and KYC remediations are the equivalents of a regulatory vote of no confidence. They can be incredibly disruptive, painful and can cost millions of dollars to implement. They are extreme measures that are taken when regulators have seen no improvement in succeeding regulatory exams or sometimes happen without warning when a criminal investigation reveals how an institution was at the center of a large scale money laundering or dollar clearing criminal enterprise and their anti-money laundering or sanctions compliance program and the controls underlying ..read more

Beginning in November 2012 with the publication of A Resource Guide to the U.S. Foreign Corrupt Practices Act (commonly referred to as the FCPA Resource Guide), the U.S. Department of Justice and the Securities Exchange Commission have regularly been publishing useful and informative guidance on the elements of effective compliance programs and the Department and the Commission’s expectations. Following the publication of the FCPA Resource Guide, the DOJ Fraud Section published another important document in February 2017 entitled “Evaluation of Corporate Compliance Programs”. It has ..read more

Part 2 of the special edition episode we continue the discussion of the most comprehensive and successful financial investigation and asset search in history; The Madoff Ponzi Scheme. For more information visit: https://fraudeatsstrategy.com ..read more

In the second part of this series, we discuss some important work my guests are involved with at the IBA’s Subcommittee on Non-trial Resolutions of Foreign Bribery Cases regarding the growing international use of settlements to resolve anti-corruption cases. For more information visit: https://fraudeatsstrategy.com ..read more

In this episode, we’re going to talk about the inter-relationship between major investigations and crisis communications. So much of crisis management planning and crisis communications is about thinking through various scenarios that could play out and then formulating a game plan for each.   For more information visit: https://fraudeatsstrategy.com ..read more

In this episode, we’re going to discuss the Anti-Money Laundering Act of 2020 (AMLA 2020). This is the most comprehensive set of reforms to U.S. anti-money laundering (“AML”) laws since the passage of the USA PATRIOT Act in 2001. While there is a lot to the Act, there are some important changes and enhancements that should have an immediate and long-lasting impact on anti-money laundering.  For more information visit: https://fraudeatsstrategy.com ..read more

The Carrasco case is a cross-border financial crime that is worth revisiting. Its lessons remain as relevant today as they were in 1998 when the fraud first erupted. For more information visit: https://fraudeatsstrategy.com ..read more