The United Arab Emirates (“UAE”) has long been at the forefront of embracing technological and financial innovation. For example, Dubai has emerged as a global hub for virtual assets (“VAs”) and cryptocurrencies. Earlier this year, the Dubai Virtual Assets Regulatory
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How Independent, Internal Investigations and Culture Assessments Can Enhance Sports Programs
Following allegations and complaints of hazing in its football program, Northwestern University retained a former United States Attorney General to conduct an internal review of the allegations and provide an analysis and risk assessment into the Athletic Department’s culture. While
FCA Investigates Bank Account Closures, Including for PEP Customers
Following concerns raised by the government of the United Kingdom (“UK”) about freedom of expression and the provision of banking services, the UK’s financial watch dog, the Financial Conduct Authority (“FCA”), recently commenced an investigation into bank account closures. This
New UAE Rule Regarding the Mandatory Attestation of Import Invoices Could Help Combat TBML
The United Arab Emirates (“UAE”) has recently implemented a new compliance requirement related to the international importation of goods. Specifically, pursuant to UAE Cabinet Resolution No. 38 of 2022 on the Attestation of Documents, Commercial Invoices and Certificates of Origin
DOJ’s Focus on Pandemic Relief Fraud Continues
The Department of Justice made a major announcement last week that demonstrates that it is serious about finding those who defraud various COVID-19 relief programs and holding them accountable to the fullest extent of the law.
Over the course of
UAE Court Dismisses Request to Extradite the Gupta Brothers to South Africa
In our previous post, here, we explained how the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) used its authority under the Global Magnitsky Human Rights Accountability Act (“GloMag”) to sanction brothers Ajay, Atul and Rajesh
United States Departments of Treasury, Commerce, and Justice Issue “Tri-Seal” Compliance Note on Voluntary Self-Disclosures of Potential Violations
Earlier this year, we published a post on the first Tri-Seal Compliance Note (“First Note”) issued by the United States Department of Justice’s (“DOJ”) National Security Division (“NSD”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the
Supreme Court Restricts the Scope of the Aggravated Identity Fraud Statute
Earlier this month, the Supreme Court of the United States decided Dubin v. United States, No. 22-10, 2023 WL 3872518, at *1 (U.S. June 8, 2023), in favor of the defendant. Justice Sonia Sotomayor wrote the opinion for the Court,
Supreme Court Clarifies Knowledge Requirement for False Claims Act Liability
Earlier this year, we previewed two significant False Claims Act (FCA) cases before the U.S. Supreme Court, United States ex. rel. Schutte v. SuperValu, Inc., No. 21-1326 (“SuperValu”), and United States ex. Rel. Proctor v. Safeway, Inc., No. 22-111 (“Safeway”).
Can a Private Person Defraud the Public of Honest Services?
Last month in Percoco v. United States (U.S. May 11, 2023), the Supreme Court reversed the petitioner’s judgment of conviction for conspiracy to commit honest-services wire fraud for allegedly accepting $70,000 from a developer in return for asking a state