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Brian Frazier by 9ZdMKlU

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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

 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

          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

        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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