A View on Corruption From Ukraine

Ukraine

Earlier this week I recorded our usual Compliance Into the Weeds podcast with my friend and colleague Tom Fox, plus a special guest: Timur Khasanov-Batirov, a compliance officer and anti-corruption officer in Ukraine. Given the importance of the war in Ukraine, our conversation with Khasanov-Batirov deserves its own written post as well. Several points are…

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FinCEN Offers Red Flags on Russia

Today we return to risks arising from the Ukraine crisis, because FinCEN has just published an alert warning financial firms to watch for transactions that might actually be Russians trying to avoid Western sanctions — including a list of red flags that AML compliance functions should keep on the radar screen. FinCEN published the 10-page…

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Ukraine Compliance Risks: A List

Ukraine

In our previous post we paused to consider some of the larger, more existential challenges to corporate ethics programs raised by Russia’s invasion of Ukraine. Today I want to shift to some of the practical compliance challenges — because those challenges are many and diverse, and compliance professionals need to start putting them into a…

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Thoughts on the Ukraine Crisis

Ukraine

Years ago — no, wait, it was last Wednesday — I planned to have a post today about the SEC enforcement action against Baxter International. We all know what happened next, and after that, what compliance professional can focus on internal controls right now?  Since Vladimir Putin invaded Ukraine last week, I’ve been trying to…

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