Pisa-Relli OFAC Facilitation (October 2011)
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The document discusses OFAC regulations regarding facilitation prohibitions and the challenges they pose for compliance. It defines facilitation broadly as any action that could help bring about a prohibited activity. This creates uncertainty, as even remote or indirect support of sanctions targets risks violation. Key challenges include determining the independence of foreign subsidiaries and the level of entanglement that is permitted with sanctioned countries. Compliance requires understanding all aspects of transactions to avoid any connection to prohibited activities.
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Additional laws and harsher penalties on financial fraud can eliminate or mitigate financial fraud, continued
Since the corporate scandals the SOX Act of 2002 sought to protect retail investors from financial statement fraud. Sentencing guidelines have changed dramatically because of Sarbanes-Oxley. For example, wire and mail fraud previously carried maximum five-year sentences, and that was increased to 20 years under the legislation.
The increase in the length of sentences for white-collar crimes now puts many of these crimes ahead of crimes such as drug trafficking and manslaughter. Some question the fairness of this. While financial crimes can cost millions or billions of dollars, to some it still seems irrational to make those prison sentences harsher than the sentences for violent crimes. Others recognize the widespread financial devastation even one white-collar crime can cause, and hope that lengthy sentences will serve as a powerful deterrent.
3
Shallow sentencing should be examined closer
Limited resources tendency to focus on violent crimes
Direct involvement cooperation lighter sentencing
The publicity of fraud
Additional laws and harsher penalties on financial fraud can eliminate or mitigate financial fraud, continued
The fact remains that shallow sentencing should be examined closer. Lawmakers, judges, and prosecutors owe it to consumer and victims to work toward a system that is fair and equitable ...
FATCA MNC Checklist final 2015
- Multinational corporations need FATCA compliance programs to ensure all necessary FATCA classifications, documentation, monitoring, and reporting are completed. This involves analyzing the organization's structure, payment flows, and operational procedures of each entity.
- Failure to comply with FATCA obligations could result in 30% withholding on U.S. payments made to foreign individuals and entities, as well as penalties and interest.
- Every entity within an organization must be reviewed to determine its FATCA classification as a foreign financial institution, non-financial foreign entity, or U.S. withholding agent in order to meet compliance and documentation requirements.
Customer Due Diligence: Improving Screening Processes for OFAC Entities and O...
Update on current OFAC Screening Requirements and How to Improve the Screening Processes as part of your overall Customer Due Diligence Program.
For more information about this topic, please contact SHAUN HASSETT at due_diligence@att.net
"Common sense not so common"
Regulators and financial intelligence units are tasked with challenging jobs to fight money laundering and terrorism financing, but some have room for improvement. Financial institutions observe that some regulators and units give unfavorable audit reports not necessarily due to legal breaches, but because of subjective methods rather than proper risk assessment. Excessive compliance costs are incurred without clear evidence that they reduce financial crimes. Regulators and units should ensure regulatory actions have benefits exceeding costs to avoid counterproductive policies. Proper risk understanding and mitigation is important over prescriptive rules and one-size-fits-all approaches.
Main Legal Risk Issues Facing Entrepreneurs | Virginia Suveiu | Lunch & Learn
About UCI Applied Innovation:
UCI Applied Innovation is a dynamic, innovative central platform for the UCI campus, entrepreneurs, inventors, the business community and investors to collaborate and move UCI research from lab to market.
About the Cove @ UCI:
To accelerate collaboration by better connecting innovation partners in Orange County, UCI Applied Innovation created the Cove, a physical, state-of-the-art hub for entrepreneurs to gather and navigate the resources available both on and off campus. The Cove is headquarters for UCI Applied Innovation, as well as houses several ecosystem partners including incubators, accelerators, angel investors, venture capitalists, mentors and legal experts.
Follow us on social media:
Facebook: @UCICove
Twitter: @UCICove
Instagram: @UCICove
LinkedIn: @UCIAppliedInnovation
For more information:
cove@uci.edu
http://innovation.uci.edu/
Ethics in Turnaround Situations
Here is our ppt deck from the June 6th TMA presentation in Chicago. Thanks to my fellow panelists: Dave Gozdecki, Reid Schar and Jeff Vogelsang. Attendees received 1.5 hrs CE
ECI FIRPTA - OPG Presentation 2015-06-24 FINAL DRAFT
This document provides a summary of key concepts regarding effectively connected income (ECI) and the Foreign Investment in Real Property Tax Act (FIRPTA) for alternative investment managers. It discusses how certain investment and business activities conducted in the US, such as direct lending, loan origination, investments in partnerships, and interests in US real property, can generate ECI and be subject to US taxation. It also notes that otherwise safe harbored investment income and gains could be recharacterized as ECI if the underlying activities constitute a US trade or business. The document cautions managers to consider facts and circumstances carefully to avoid unintentionally generating ECI.
Due diligence report 20150414
This document discusses due diligence in international transactions. It begins with an introduction that defines due diligence and its importance when evaluating potential investments, mergers, or acquisitions. It then discusses the different types of due diligence, including legal, financial, and commercial due diligence. The document also outlines the key steps in a typical due diligence framework. Finally, it emphasizes the importance of due diligence for reducing risk and gaining valuable information when conducting international business transactions.
Oa Presentation Pi Apr March 2009
The document discusses combating fraud and corruption in projects funded by IFAD. It outlines IFAD's zero-tolerance anti-corruption policy, which establishes that all significant allegations will be investigated and appropriate sanctions applied if proven. It describes types of fraudulent practices, red flags to watch for, practical prevention methods, and protections for whistleblowers who report issues.
Managing the country programme for results: Audit - Karen Juergens
Managing the country programme for results: Audit - Karen JuergensIFAD International Fund for Agricultural Development
The document discusses combating fraud and corruption in projects funded by IFAD. It outlines IFAD's zero-tolerance anti-corruption policy, which establishes that all significant allegations will be investigated and appropriate sanctions applied if proven. It describes types of fraudulent practices, red flags to watch for, practical prevention methods, and protections for whistleblowers who report issues.Federal Trade Commission Act Unfair or Deceptive Acts or Practices
This document discusses unfair or deceptive acts or practices (UDAPs) prohibited under Section 5 of the Federal Trade Commission Act. It provides standards for determining what constitutes an unfair or deceptive act or practice, including causing substantial consumer injury, inability to reasonably avoid injury, and benefits not outweighing costs for unfair acts, and acts likely to mislead reasonable consumers and affect their decisions for deceptive acts. The document also discusses the role of consumer complaints in identifying potential UDAPs and institutions' responsibilities to properly handle such complaints.
CECO ISM_Forward_Scan_6_12
The document discusses the strategic value of having a Chief Ethics & Compliance Officer (CECO) that is independent from the legal department. It notes that the CECO's role has emerged to address issues where compliance was previously handled by legal or HR. The CECO should report directly to the board rather than legal to avoid conflicts between US and foreign laws. Maintaining independence of the CECO and legal functions is important for companies operating in high-risk regions to manage compliance with anti-bribery, money laundering, and corruption laws.
CECO ISM_Forward_Scan_6_12
- The document discusses the strategic value of having a Chief Ethics & Compliance Officer (CECO) who is independent from the General Counsel in order to effectively manage legal and ethical risks across different jurisdictions.
- It argues that the CECO's role should be autonomous and separate from the GC to avoid conflicts of interest that could weaken compliance processes and a company's ability to comply with anti-corruption laws.
- The strategic collaboration between the independent CECO and GC is vital for companies to adequately manage their global operations and facilitate compliance with various US and foreign laws.
AlyousifName Mohammed AlyousifProfessor Conne FarrelCour.docx
Alyousif
Name :Mohammed Alyousif
Professor: Conne Farrel
Course:ENG-100
Date: 11/6/2016
Use of Blackout Periods to Curb Insider Trading
A couple of years back in 2012 a Manhattan office linked to the United States Attorney initiated criminal investigations to establish whether corporate executives from a list comprising of seven different companies engaged in insider trading by trading shares of their own company’s stock. Since then, it is uncommon to pick up a newspaper and miss an insider trading investigation. At a time when a former Yahoo executive pleaded guilty of committing a securities fraud, another trial was underway involving the director of Goldman Sachs who was accused of leaking insider information of both Procter & Gamble and Goldman Sachs to a friend.
In addition, former hedge fund Raj Rajaratnam has been convicted for insider trading proving that Securities and Exchange Commission is putting a lot of effort in investigating and prosecuting cases of insider trading. However, this does not help restore investor confidence in the financial sector. Some other corporate level strategies should be instituted to prevent governmental interventions in the issue. One such appropriate way is use of “blackout periods” to check flow of sensitive information during trading periods.
In all manner and fashion insider trading undermine investor confidence in relation to integrity and fairness of the securities market. Because of this, all jurisdictions around the world have legislations dealing with insider trading. Undisputedly, the United States has been the longest serving victim of the issue of insider trading. Most of the studies carried out on the issue are carried out in the US and some of the toughest legislations formed to deal with the matter originate from the United States of America (CFA Institute 4). Inside trading has a huge influence in the American financial market and other markets around the world.
The concept of insider trading has two major adverse effects. First, it injures investors by undermining their confidence regarding the financial markets of a company, country or a state. Regarding investors, inside trading makes them trade at a “wrong price.” In other words, an investor is duped to make a bad purchase or sale. Even though, this type of effect has been down played it has significant impacts on the change of perception of investors in any particular securities market. Secondly, inside trading injures Issuers this is because it will delay corporate plans by delaying transmission of information to provide sufficient time for manipulation of stock prices (Anderson 358). As a result, a company in question suffers massive reputation damage when the issue becomes common knowledge.
In addition, insider trading is plain theft. Therefore, inside trading is an issue to be addressed not only by the regulatory frameworks provided by the legislative bodies but also individual corporate initiatives. Form the statist.
Resolving Shareholder Disputes (Series: Complex Financial Litigation 2020)
When business owners come to the point where they simply can’t see eye to eye, success can become unfeasible. Disputes between business owners can arise from any number of issues and have varying impacts on the actual business, ranging from simple distraction to total dissolution. Depending on the business and circumstance, the means for resolution may or may not be provided for in the relevant by-laws or shareholder agreement. In this webinar, the expert panel discusses different types of shareholder disputes and corresponding remedies, including alternative dispute resolution, buy-sell agreement provisions, and share valuation considerations.
To listen to this webinar on-demand, go to: https://www.financialpoise.com/financial-poise-webinars/resolving-shareholder-disputes-2020/
Fatca rules explained
1) FATCA (Foreign Account Tax Compliance Act) requires foreign financial institutions to report information about financial accounts held by US taxpayers to the IRS. FFIs must enter agreements to share this information or face penalties like tax withholding.
2) Complying with FATCA's requirements will be extremely costly and challenging for financial institutions. It will require changes to internal systems, processes, and procedures across organizations.
3) FATCA will impact more than just financial institutions. All companies that make US-sourced payments abroad will need to modify their practices to comply with FATCA by 2013 to avoid penalties.
AICPA MS - Article MKS2016
1) CPAs and other financial professionals are now considered fiduciaries under new regulations, requiring them to put their clients' interests first.
2) Record keeping is crucial to demonstrate that all work was conducted within compliance guidelines, including documenting all client meetings and the process for insurance transactions.
3) A lawsuit awarded $14.2 million to a plaintiff after two reputable firms provided dramatically different calculations for life insurance premiums to maintain the same benefits, illustrating the risks of relying on common industry practices. Proper application of prudent investor principles could have avoided litigation.
Johnson ploiceies
The document outlines Johnson & Johnson's policy on business conduct. It states that all managers and employees are responsible for complying with and enforcing the policy. Managers must ensure employees are aware of and comply with the policy, and employees must report any prohibited or unlawful acts. The policy addresses areas like conflicts of interest, compliance with laws and regulations, political contributions, and accurate record keeping.
LEGAL ETHICS – BEST PRACTICES 2022 - How to Avoid Malpractice & Disciplinary ...
This webinar presents basic practice pointers to avoid malpractice and disciplinary actions, and how to respond to claims of malpractice or unethical behavior if they arise. The panel also discusses the role that malpractice insurance plays in these situations and the ramifications of a malpractice judgment or disciplinary action. Model Rules addressed may include: those that govern the client-lawyer relationship (Rules 1.1 through 1.10; 1.13; and 1.16); those that that speak to transactions with persons other than clients (Rules 4.1 through 4.4); those that govern the responsibilities of managing and supervisory lawyers, subordinate lawyers, non-lawyer assistance, independence, unauthorized practice of law, and multijurisdictional practice (Rules 5.1 through 5.5); and those that govern communication, including advertising and solicitation of clients (Rules 7.1 through 7.5).
Part of the webinar series: LEGAL ETHICS – BEST PRACTICES 2022
See more at https://www.financialpoise.com/webinars/
Birthing Unicorns: A Practical Guide to Legal Aspects of Launching Digital Me...
This document provides a summary of key legal considerations for launching a digital media startup. It discusses implementing structures that facilitate raising capital and liquidity events like acquisitions or IPOs. Some of the main points covered include choosing the right legal entity and location, capitalization, intellectual property protection, employment compliance, and regulatory issues. The document emphasizes the importance of being prepared for diligence from investors or acquirers by having documentation like financials, capitalization tables, and contracts in order.
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Main Legal Risk Issues Facing Entrepreneurs | Virginia Suveiu | Lunch & Learn
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