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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

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Panel Session 5: Compliance & Enforcement

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  1. 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

  2. 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

  3. 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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