Panel Session 5:
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Panel Session 5: Compliance & Enforcement. Enforcement Actions No set timeframe to start Depends on facts of case Whistleblower/cooperating witnesses SAR/FIU referral - Predicate crime Enterprise theory as blueprint - Trace funds - Concealment - Facilitation

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Panel Session 5: Compliance & Enforcement

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Panel session 5 compliance enforcement

Panel Session 5:

Compliance & Enforcement

  • Enforcement Actions

  • No set timeframe to start

  • Depends on facts of case

  • Whistleblower/cooperating witnesses

  • SAR/FIU referral

  • - Predicate crime

  • Enterprise theory as blueprint

  • - Trace funds

  • - Concealment

  • - Facilitation

  • Demands aggressive internal compliance programs/investigations

Brian Frazier, Resident Legal Advisor, UAE and the Middle East, US Department of Justice


Panel session 5 compliance enforcement

Panel Session 5:

Compliance & Enforcement

Internal Compliance Programs/Investigations (1 of 2)

  • Outside counsel/forensic professionals

  • Objective/specialized

  • Attorney-client privilege/work product doctrine

  • No conflicts

  • Know applicable standards

    - Criminal laws/industry regulations

    - Professional codes and ethics

    - Company handbook/employee code of conduct

Brian Frazier, Resident Legal Advisor, UAE and the Middle East, US Department of Justice


Panel session 5 compliance enforcement

Panel Session 5:

Compliance & Enforcement

Internal Compliance Programs/Investigations (2 of 2)

  • Evaluate available information

  • Employee witnesses

  • Telephone/email/correspondence

  • Stored electronic data files

  • Self-reporting to authorities

    - Must evaluate prospects

    - Could minimize exposure

    - Government success in ML cases

Brian Frazier, Resident Legal Advisor, UAE and the Middle East, US Department of Justice


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