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The Department of Justice (DOJ), through the U.S. Attorney’s Office (USAO) for the Southern District of California, recently announced a non-prosecution agreement with a Las Vegas casino, which forfeited over $130 million under the agreement. The agreement settled criminal allegations that the casino conspired with unlicensed money transmitting businesses (MTBs) worldwide to transfer funds for its financial benefit. This announcement is the latest example of the DOJ’s expanding focus on alleged money-laundering activities involving MTBs and international transfers of funds, particularly transfers connected with mainland China and mainland Chinese-related criminal activity.

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Over the last several years, enforcement authorities including the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have aggressively pursued corporate misconduct, particularly in the areas of cybersecurity, artificial intelligence, financial fraud, corruption and sanctions. As a result, public and private companies, as well as their boards, have faced—and continue to face—increasingly complex compliance obligations. In a recent article for Governance Intelligence, colleagues David Oliwenstein, Tony Phillips and Adam Goldberg provide insights on notable DOJ and SEC enforcement trends, what boards need to know, and recommendations on how to mitigate the risk of government investigations.