Kreller Forensics 
Blog
Self-Reporting: A Step Forward
At the 34th International Conference on the Foreign Corrupt Practices Act on November 29, 2017 Deputy Attorney General Rod Rosenstein announced the FCPA’s new Corporate Enforcement Policy (CEP). This new policy will make permanent and expand upon the Obama administration’s FCPA Pilot Program under which the Department of Justice would “consider” declining to prosecute companies that self-report violations and comply with investigations.
Mohammed Bin Salman is described by his supporters as a reformist with a desire to transform and modernize Saudi Arabia, get rid of extremist ideologies, ease restriction on women, and root out corruption. On the other hand, he is described by more traditional and conservative Saudis who disagree with his views as someone attempting to consolidate his power by purging political leaders and business leaders from the kingdom.
The leaks include holdings of corporate giants like Apple, Facebook, Disney, and McDonalds; current world leaders including Queen Elizabeth II and Prince Charles; sports team owners like Robert Kraft and Micky Arison; and even celebrities such as U2 singer Bono. Also named are US Secretary of Commerce Wilbur Ross and 12 others connected to the Trump Administration. Ross in particular has been named as a financial stakeholder in a Russian shipping firm with connections to Russian President Vladimir Putin.
Lone Star National Bank was fined $2 million dollars, though an earlier $1 million penalty the bank had already paid will credited toward that total. This case is interesting because FinCEN found no indication of actual money laundering; rather they noted suspicious activity involving a Mexican depositor, and found that Lone Star had not put in place adequate controls to serve foreign clients. The FinCEN assessment says "Without sufficient internal controls or experienced BSA staff, the Bank engaged in high-risk foreign correspondent banking services without conducting appropriate due diligence, and without adequately monitoring and reporting suspicious activity." This underscores the need to conduct due diligence on foreign clients.
She was extremely well known and popular in Malta. Her blog entries sometimes attracted more readers than the combined circulation of Malta's newspapers. The website Politico has described here as "a one woman wiki leaks."
Her work focused on rooting out corruption and holding politicians accountable. Her work focused not only on politicians, but also on banks that facilitated money laundering, and Malta's online gaming industry and it's links to organized crime. In the past several years she had written extensively about revelations regarding Maltese politicians that came from Panama Papers. Her work on the Panama Papers is credited with causing Malta's Prime Minister, Joseph Muskat, to have to go to the polls a year early.
The penalties stem from actions taken by the company after it purchased Coscom LLC, a company providing telecom services in Uzbekistan. After the purchase the company paid numerous bribes to government officials, including Gulnara Karimova, daughter of late Uzbek president Islam Karimova, in order to expand it's share of the Uzbek telecom market. Telia allegedly made payments to Karimova alone of up to $300 Million. A number of companies were also implicated in a bribery scandal involving Gulnara Karimova and dozens of her associates. The Amsterdam based company VimpelCom was also implicated in the bribery scandal in Uzbekistan, and itself paid $795 Million in penalties to US and Dutch authorities last year.
More recently the legislature passed a law to protect President Morales from prosecution, which triggered protests and the constitutional court stepping in and provisionally blocking the law from taking effect. On Thursday the Guatemala's congress announced it would be repealing the laws. What happens next is anyone's guess, but the protests were reported to be quite large, and many say that they are now disappointed in Morales. Morales was elected as an outsider who would clean up corruption, and many say they feel betrayed by the recent actions of Morales and the legislature. If the government pushes things too far it may face huge protests. Two years ago the capitals central plaza was filled with protesters for 20 straight weekends to protest corruption, and led to the resignation of former President Otto Pérez Molina. It's anyone's guess if the same thing will happen to President Morales, but it's clear that many people in the country take anti-corruption efforts seriously.
Menendez is accused of accepting lavish trips, jet flights, gifts, and campaign donations from Saloman Melgan, a Florida-based ophthalmologist, in exchange for political favors. These favors include helping Melgen’s girlfriends obtain US visas, attempting to resolve an $8.9 million billing dispute between Melgen and Medicare, and helping Melgen profit off a port security contract in the Dominican Republic. Menendez, who is the first US Senator to stand trial for bribery since 1981, asserts that he has never dishonored the public office and believes that he will be exonerated.
GTOs are aimed at curbing the use of real estate transactions to launder money. Title Insurance companies in the effected areas are required to keep more detailed records on, and report to FinCEN, the ultimate beneficial owners involved in real estate transactions made with cash. Some areas of the United States have become notorious as places where individuals and organizations can launder money through cash real estate purchases made via shell companies and other means of obfuscating their identity. This order shines some sunlight on these transactions.
