Beginning in 2018, DOJ criminally charged several of Defendants’ employees…
Britain’s Financial Conduct Authority fines Commerzbank AG, London Branch £37,805,400 (~$46,684,640).
Overview On June 17, 2020, despite having found no incidences of a “financial crime” Britain’s Financial Conduct Authority (FCA) fined Commerzbank AG, London Branch £37,805,400 (~$46,684,640) for inadequate controls and procedures related to the bank’s financial crime control framework. The fine is to be paid no later than July 1, 2020. From the FCA’s 50-page […]
DoJ updates Evaluation of Corporate Compliance guidance
Civil Monetary Penalty Guidance On May 28, 2020 James McDonald, Director of Enforcement at the Commodity Futures Trading Commission (CFTC) gave a speech at the Futures Industry Association addressing the issues of penalties and penalty guidance, following up on a memo to staff (see here). This marked the first time in 25 years the CFTC […]
Earlier this year the Department of Justice (DoJ) issued two publications for prosecuting attorneys to provide guidance on assessing the effectiveness of corporate compliance programs. The two publications (April 2019 and July of 2019) further develop and update the “Evaluation of Corporate Compliance Programs,” issued by the Criminal Division’s Fraud Section released in February 2017 […]