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Transparency Priorities for 2014
January 4th, 2014
The New Year is a great time for resolutions. Of course most of these resolutions are made on a personal basis. But resolutions can also be made on a national and international level. So in that spirit, here are five resolutions from the FTC and some of our Coalition members. These reforms and priorities, if
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Behavioral Economics and Lessons for FCPA, AML, and Tax Compliance
July 10th, 2013
Under the standard economic theory of crime, compliance with laws is a mix of two important factors. One: the penalty that results if the offender is caught and 2: the probability of the offender getting caught in the first place. If the fine is proportional to the crime, but the probability of being caught is almost certain, few will risk it. In the same way, if the probability of being caught is low, but the penalty is very high, again few will risk it. Gary Becker—the libertarian economist who wrote Crime and Punishment: An Economic Approach, an...
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Liberty Reserve, Money Laundering, and Implications for Bitcoin
June 26th, 2013
In April, I argued Bitcoin, one of the world’s most mainstream currencies currently operating, may become a viable, sizeable, and more dangerous alternative to offshore accounts for money laundering and tax evasion. I argued the U.S. government isn’t paying close enough attention to the growing threat posed by these currencies. Yet, just a month later, the Department of Justice arrested the founders of Liberty Reserve, another digital currency, and charged them with money laundering. It might seem I was wrong. I say not so fast. For counter-intuitive reasons, Bitcoin still poses a more serious, and long-term, threat than currencies...
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A Speed Bump, Not a U-Turn
March 6th, 2013
In December of last year the U.S. Department of Justice discovered that HSBC, a large British bank, “willfully failed” to apply money laundering controls to at least $881 million in drug trafficking proceeds from Mexico and covered up illegal transactions for Burma, Iran, Sudan, Cuba, and Libya. To escape criminal charges, HSBC admitted to wrongdoing and paid a record $1.92 billion settlement. Yet despite this massive offense, not a single person went behind bars as a result. This wasn’t just a failure of the system or the anonymous bureaucracy of a massive corporation. The investigation revealed that senior HSBC officials...
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