Bribes, both foreign and domestic, are often mischaracterized in companies’ books and records. Under this provision, issuers must make and keep books, records, and accounts that, in reasonable detail, accurately and fairly reflect an issuer’s transactions and dispositions of an issuer’s assets.
AML Whistleblower Act Rulemaking: Key Recommendations for FinCEN’s Final Regulations
In a 2023 letter to Attorney General, Secretary of the Treasury, and FinCEN Director, Kohn argued that the new AML whistleblower regulations must not only replicate the existing SEC and…
