The standard for finding a violation of the record-keeping and internal controls provision is not materiality but reasonableness, such that the improper recorda- tion of a transaction could be immaterial from a federal securities law perspective but could still be a violation of the FCPA (if ...
This is a United States law prohibiting individuals and firms in the United States from bribing foreign officials to further a business deal.
The SFO have said that they will be looking at examples of lavish hospitality. Corporate hospitality will need to be for an obvious and legitimate commercial purpose. What will be lavish will be a question of degree. What might be OK for one customer is likely to be different for another. ...
The source of funds (SOF) is the origin of a person’s money or financial assets. In establishing the source of funds, firms must seek to understand not only where funds came from (in terms of the account from which they were transferred) but the activity that was involved in generating...
What is Due Diligence? Due Diligence Meaning or definition of due diligence: the concept of due diligence enshrined in German law refers to theexercise of reasonable care in the course of business. Adue diligence checkinvolves careful investigation of the economic, legal, fiscal and financial circu...
Understanding the nature and purpose and compiling risk profiles of customer relationships Monitoring suspicious transactions and updating customer information CDD may try to uncover and counter money laundering patterns such as layering and structuring, also known as “smurfing”—breaking up large transacti...
Understanding the nature and purpose and compiling risk profiles of customer relationships Monitoring suspicious transactions and updating customer information CDD may try to uncover and counter money laundering patterns such as layering and structuring, also known as “smurfing”—breaking up large transacti...
The purpose of the Supplier Code of Conduct (ASCC) is to ensure that working conditions in the industry supply chain are safe, workers are treated with respect and dignity, and business operations are environmentally responsible. 《供应商行为准则》的目的是为了以确保行业供应链的工作环境安全,劳工...