Is Bank De-Risking Choking Caribbean Growth Prospects?

Is Bank De-Risking Choking Caribbean Growth Prospects? Richard Wiedis, Diaz Reus Washington Partner, and Javier Coronado, Associate Attorney at Diaz Reus Bogota, explain: “Global financial institutions (GFIs) are increasingly terminating or restricting correspondent relationships with Caribbean banks based on their concerns about the costs of complying with AML/CFT regulations, including customer due diligence and know-your-customer…

FCPA Alert: U.S. Government Still Contends That The FCPA Applies Extraterritorially

In its recent and widely publicized opinion in United States v. Hoskins, the United States Court of Appeals for the Second Circuit (New York) held that criminal liability under the FCPA should not apply to a nonresident foreigner if the crime was not committed within the U.S. and the individual was not an officer, director, employee, or stockholder of an American company, or otherwise had no agency relationship with a U.S. person…