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).
   [1]https://www.mondaq.com/unitedstates/white-collar-crime-anti-corrupti
   on--fraud/1322846/what-every-multinational-company-should-know-about--a
   nti-corruption

References

   1. https://www.mondaq.com/unitedstates/white-collar-crime-anti-corruption--fraud/1322846/what-every-multinational-company-should-know-about--anti-corruption