What about the $100M Coinbase compliance deal? We stil are not getting any answers from NY-DFS on this and it would appear that the Superintendent is an attorney, formerly of a firm who represents Coinbase. xNY.io has dreams of being a New York State digital asset exchange show horse. We have a whole conflicts folder and everything... ---- What Areas Present Anti-Corruption Risks for My Company? Ineffective oversight of third parties interacting with government officials is a major driver of anti-corruption enforcement actions. Companies that employ consultants, agents, and distributors; that rely on a distribution or franchise model; or that maintain non-U.S. joint ventures are at especially high risk, especially if they engage third parties to obtain government permits, licenses, or otherwise have frequent contact with government officials. The presence of many State-Owned Enterprises (SOEs) in China and developing countries raises FCPA concerns, as even SOEs operating as ordinary commercial entities trigger FCPA requirements, as every employee is treated as a government official under the FCPA. In the M&A space, the DOJ and SEC have been aggressively asserting claims against acquiring companies, often using theories of successor liability, for pre-merger conduct of their targets that violated the FCPA. The DOJ and SEC have emphasized the need to conduct regular anti-corruption compliance risk assessments, particularly after events that could significantly impact business operations such as the global COVID-19 pandemic, entrance into new markets, or a corporate acquisition. Such events generally introduce new, expanded, or revised internal controls; increased governmental interactions; new employees; unique jurisdictional requirements; or new business partners and third-party relationships, each of which may present novel or heightened anti-corruption risks. Global cooperation and coordination between U.S. and foreign enforcement agencies has increased appreciably, with countries often sharing information (as well as simultaneously imposing fines and penalties). https://www.mondaq.com/unitedstates/white-collar-crime-anti-corruption--frau...