Josh Wallenstein

UPDATE! New U.S. Beneficial Ownership Reporting Obligations

Designed by Freepik Starting January 1, 2024, most US businesses will have one (1) year to file their Beneficial Ownership Report. As noted in our blog, “ALERT! Your New US Beneficial Ownership Reporting Obligations!”:  beginning January 1, 2024, companies will be subject to increased reporting requirements. Specifically, new regulations will require the reporting of information

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ALERT!  Your New US Beneficial Ownership Reporting Obligations!

Designed by Freepik Your questions:  We’re glad you asked, read on for answers! The Genesis of Reporting Obligations Beginning January 1, 2024, companies will be subject to increased reporting requirements. Specifically, new regulations will require the reporting of information about company’s “beneficial owners” to the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN). These changes come

ALERT!  Your New US Beneficial Ownership Reporting Obligations! Read More »

Am I at Risk of Compensation Clawbacks?

Clawbacks are contractual provisions that restore or recoup disbursed monies inappropriately awarded.  In the anticorruption compliance world, they mostly mean “disgorging” compensation derived from improper or illegal behavior.  (If, for example, you receive a performance bonus based on sales that you obtained through illegal bribes…perhaps you should return that bonus.) You, dear Reader, may remember

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The 2022 Corruption Perceptions Index:  Helpful in Calibrating Risk? 3 Deep Thoughts… And Some Follow Up!

Some of us are old enough to remember Jack Handey.  Well, Dear Reader, I’m not as funny as Saturday Night Live…but I have fewer commercials. Every year, Transparency International publishes the Corruption Perception Index (“CPI”), an exercise in measuring relative levels of perceived public sector corruption.  Of course, there are other indices of corruption, e.g.,

The 2022 Corruption Perceptions Index:  Helpful in Calibrating Risk? 3 Deep Thoughts… And Some Follow Up! Read More »

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