Perspective: How White Collar Criminal Defense Work is Changing
If the recent proliferation of taskforces and initiatives is any indication, the aggressive cross-border expansion of white-collar crime enforcement is only intensifying. Indeed, in March 2015, the FBI announced three new squads dedicated to investigating FCPA- and kleptocracy-related violations globally. In November 2015, the DOJ’s Fraud Section created a Compliance Counsel position to investigate corporate compliance programs. In January 2016, the Financial Crimes Enforcement Network issued orders requiring disclosure of the natural persons behind companies purchasing high-value real estate in Manhattan and Miami-Dade. Since 2011, the DOJ’s Kleptocracy Asset Recovery Initiative has been seizing high-level foreign officials’ illicit assets, and its efforts are only increasing.
Federal agencies undoubtedly intend to secure a significant return on investment, and have been putting these new resources to use.
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