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On NFTs, Treasury Comes Out Swinging

Posted  02/8/22
NFT and cash
The Treasury Department recently issued a Report on money laundering in the art markets.  To no one’s surprise, Treasury found the art market to be an “attractive” one for money launderers, given the “the high-dollar values,” “ease of transportability,” “long-standing culture of privacy,” and “increasing use of art as an investment or financial asset.”  When Congress mandated the report back in...

Top Ten Financial and Healthcare Fraud Prison Sentences of 2021

Posted  01/28/22
handcuff and money
Individuals involved in financial and healthcare fraud schemes face not just civil liability, but also criminal penalties – including prison time. In 2021, the Department of Justice obtained substantial prison sentences in a myriad of cases involving healthcare and financial frauds, many of which involved convictions of the type of fraudulent schemes that whistleblowers report. Whistleblowers play an essential role...

Top Ten Federal Financial Fraud Recoveries of 2021

Posted  01/21/22
Money with Gavel and Handcuffs
While 2021 may have felt like more of the same as the pandemic dragged on, it marked some new trends in federal financial fraud recoveries. As we predicted last year, the Anti-Money Laundering Act of 2020 has heralded some large recoveries against banks. The Act also established an Anti-Money Laundering Whistleblower Program, so that whistleblowers who report financial institutions engaging in money laundering –...

Top Ten SEC and CFTC Recoveries of 2021

Posted  01/7/22
Top Ten Sign with Letters
As we recently detailed, 2021 proved to be a blockbuster year for whistleblowers under the CFTC and SEC Whistleblower ProgramsSeven of the ten largest whistleblower awards of 2021 were made to SEC and CFTC whistleblowers, including a massive $200 million CFTC award that was roughly twice as large as all prior CFTC awards combined.  In total, the SEC paid more awards—both in total dollars and individual...

The New ENABLERS Act May Be a Backdoor Way to Expand the Anti-Money Laundering Whistleblower Program

Posted  10/14/21
Hundred dollars bills pinned to clothes line
In The Hill this week, I argue that the newly proposed ENABLERS Act is a lot more powerful than even its authors seem to realize.  The proposed law would effectively expand the Bank Secrecy Act to apply the same reporting requirements currently imposed on banks to all sorts of actors who enable (get it?) money laundering: lawyers, investment advisers, accountants, art dealers, public relations firms, and the like. ...

Pandora Papers Show the Value of Financial Transparency, the Critical Role of Whistleblowers – and the Need for Additional Regulation

Posted  10/8/21
This week, the International Consortium of Investigative Journalists and its partners began publicly reporting on the “Pandora Papers,” a trove of millions of leaked documents from firms around the world that help customers set up “offshore” accounts and shell companies designed to conceal financial truths.  The leaked documents, and the extensive reporting on the documents, sheds light on the murky world of...

Catch of the Week: San Francisco Garbage Companies Cop to Bribing Corrupt City Regulator in $36 Million Deal with Feds

Posted  09/10/21
Garbage Truck Men Loading Trash Behind Truck
Three San Francisco trash and recycling companies, all Recology, Inc. subsidiaries, have agreed to pay $36 million in a corruption scheme involving substantial bribes to former San Francisco Public Works Director Mohammad Nuru. The SF Recology Group, which includes Recology San Francisco, Sunset Scavenger Company, and Golden Gate Disposal & Recycling Company agreed to a deferred prosecution deal on charges they...

Catch of the Week: Telemedicine Company Owner Charged in $784 Million Kickback Scheme

Posted  08/20/21
Doctor on computer with patient discussing medicine
Underscoring the fraud risks associated with the government’s continued expansion and loosening of restrictions on telehealth, the U.S. Department of Justice recently announced that a grand jury in New Jersey has returned a superseding indictment against the Florida owner of multiple telemedicine companies, referred to by DOJ prosecutors as the Video Doctor Network, for allegedly participating in a massive Medicare...

What the SEC can learn from its German peer BaFin

Posted  08/13/21
Building of Wirecard in Germany
The Federal Financial Supervisory Authority, otherwise known as BaFin, is Germany’s version of the U.S. Securities and Exchange Commission (SEC), a supervisory body working to ensure the functioning, stability and integrity of the German financial system. BaFin was created following a 2002 merger between Germany’s Federal Banking Supervisory Office (BAKred), the Federal Securities Supervisory Office (BAWe), and...

When the Deli’s Not Just a Deli

Posted  04/28/21
share certificate
A market mystery recently caught the attention of financial journalists and the public more generally: a New Jersey deli that is seemingly never open and reports minimal profits is—on paper at least—worth $100 million after issuing public shares.  The shareholders are few, and mostly in China.  The owners are local (the revered wrestling coach) and not (a father-son investor duo with a history of shady...
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