The attached report looks at the anti-bribery and corruption legislation of Russia, Azerbaijan, Kazakhstan, Kyrgyzstan, Turkmenistan, and Uzbekistan and reveals significant differences in law and approaches Only Russia, Azerbaijan and Kyrgyzstan also punish companies for the bribery of public officials as well as commercial bribery. In Kazakhstan, companies are punished only for the bribery of […]
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Mauritius Leaks…..July 2019 (follows Paradise, Panama, et al)
Mauritius Leaks is a cross-border investigation into how one law firm on a small island off Africa’s east coast helped companies leach tax revenue from poor African, Arab and Asian nations. Led by the International Consortium of Investigative Journalists, the investigation is a collaboration by 54 journalists in 18 countries. More than 200,000 documents from […]
Read MoreThe U.S. continues aggressive sanctions and anti-money laundering enforcement against non-U.S. banks
When assessing anti-money laundering risk and exposure, global financial institutions should be mindful of the complex landscape and assertions of broad authority by U.S. authorities and banking regulators. U.S. banking regulators, in conjunction with U.S. criminal and civil authorities, have traditionally pursued anti-money laundering and sanctions enforcement cases against multinational banks in relation to conduct […]
Read MoreMauritius leaks…..JOINT ATMC / GFM PRESS COMMUNIQUE
It has come to our attention that the International Consortium of Investigative Journalists (ICIJ), in partnership with l’Express, a local newspaper, has released a report on Mauritius (‘Mauritius Leaks’) on July 23, 2019. By the ICIJ’s own admission, their so-called “investigation” has been based on a USB key that was handed over to them anonymously. […]
Read MoreJersey Financial Services Commission issues first civil penalty
Update prepared by Mathew Cook (Counsel, Jersey) Following much anticipation, we now have a chance to review the public statement and identify key learning points for industry. The Jersey Financial Services Commission (the JFSC) has had the power to issue civil penalties since March 2015 and this week issued the first penalty. With the expansion […]
Read MoreSanne Fiduciary Services Limited (SFSL)
17 July 2019 Financial Services (Jersey) Law 1998, as amended (the FS(J)L) Code of Practice for Fund Services Business and Code of Practice for Trust Company Business (together, the Codes) 1 Action 1.1 The Jersey Financial Services Commission (JFSC) issues this public statement pursuant to Article 25(ba) of the FS(J)L. 1.2 The JFSC’s actions support […]
Read MoreCivil Financial Penaltieson Principal Persons:Methodology for determining the amount
1. Introduction a. The methodology set out in this paper describes the Jersey Financial Services Commission’s (JFSC)guideline approach to the determination of the amount of a civil financial penalty to be imposed on a principal person. The circumstances of each case will be different and the JFSC will apply each step in the methodology with […]
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