On September 26, 2019, a bipartisan group of eight Senators introduced the Illicit Cash Act[1], which, among other proposed reforms, would require certain companies to disclose beneficial ownership information to the Financial Crimes Enforcement Network (FinCEN) at incorporation and within 90 days of any change in beneficial ownership.
Led by Sen. Mark Warner (D-VA), co-sponsors to the bill include Republican Sens. Tom Cotton (R-AR), Mike Rounds (R-SD), John Kennedy (R-LA), and Jerry Moran (R-KS); and Democratic Senators Doug Jones (D-AL), Bob Menendez (D-NJ), and Catherine Cortez Masto (D-NV). This cohort of Senators – who sit on the powerful Senate Banking Committee – achieved something rarely seen in the current US political climate: bipartisanship. Though the sponsors have crossed the aisle in introducing this legislation, prospects for passage this year remain uncertain. Against the backdrop of the recently-announced House Democrats’ impeachment inquiry, lawmakers have a shrinking number of legislative days to tackle complex issues like anti-money laundering (AML) reform. What’s more, Congress must also come together to fund the government when the current Continuing Resolution expires on November 21. Looking ahead, the Illicit Cash Act is a step toward meaningful AML reform but it still has a long way to go. Below, we discuss what’s in the bill, outside support, uncertainty for AML reform in the House, and next steps. Continue Reading
Saying it will accelerate complex investigations, the United States and the United Kingdom proposed an historic data exchange agreement. In future, each government will be able to obtain electronic data directly from technology companies in the other country. The governments also say this first of its kind agreement will protect privacy and enhance civil liberties.
The Financial Action Task Force (FATF), an intergovernmental organization founded 30 years ago to develop and uphold policies to combat money laundering and terrorist financing, is conducting a peer review (or “mutual evaluation”) of the United Arab Emirates (UAE) this year.
A post on our Triage blog discusses a decision about the legality of changing medical billing codes in order to maximize revenue from the government. Can that be done consistent with the False Claims Act? See the discussion 
Sometimes an investigation of corporate conduct results in criminal charges. Will an insurance policy protecting Directors and Officers (D&O) pay the costs of those criminal charges? Larry Schiffer reports on a recent decision from the Eleventh Circuit interpreting Florida law. Larry’s post (here) reveals the importance of knowing the scope of your policy.
In a growing trend, the Department of Justice (DOJ) indicted two corporate executives and two licensed pharmacists for drug distribution. This is the second time in 2019 that DOJ acted to hold opioid distributors and manufacturers criminally liable for contributing to the drug crisis.
The Italian Government recently approved a bill known as the Spazzacorrotti, or “Bribe Destroyer.” The anti-establishment Movimento 5 Stelle, or Five Star Movement, which took office after campaigning to tackle bribery, has been championing the bill as a “revolution in the fight against corruption” that would allegedly save the country billions of euros. However, the same Five Star Movement may well have scored a spectacular own goal, having just become embroiled in a high-profile bribery scandal related to the construction of A.S. Roma’s new football stadium, the 52,500-seat Stadio della Roma, a project that has been beset by difficulty. 
