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Raising the Stakes

By Marjorie J. Peerce, Charles A. Stillman and Elizabeth J. Lee
February 28, 2015

The government has become increasingly aggressive in pursuing criminal claims not only against corporations, but also against in-house counsel and compliance personnel, for conduct once treated almost exclusively as civil. This trend creates situations in which a judgment call on the part of an in-house attorney or compliance officer could create real and dire personal consequences. Most recently, the U.S. Treasury Department's Financial Crimes Enforcement Network imposed a $1 million civil penalty against a money services industry compliance officer as a result of a purported failure to ensure his company's compliance with anti-money laundering laws.

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