The magnitude of the recent settlement, along with the extent and intricacy of the purported money transfers—including those involving transfers to the Chinese mainland—make it noteworthy.
Due diligence on agents, brokers, and other middlemen who help with the foreign transfer of funds into the United States must continue, as evidenced by the uptick in criminal enforcement activity.
Due diligence on agents, brokers, and other middlemen who help with the foreign transfer of funds into the United States must continue, as evidenced by the uptick in criminal enforcement activity.