0703 TCD Long Room 3


Socrates in the C-Suite: The Uses of Socratic Questioning in Corporate Compliance, Journal of Financial Compliance (2018)

Section 7 of the United Kingdom Bribery Act: A “Fair Warning” Perlustration, 43 Yale Journal of International Law Online 1 (2017)

Memorandum to the Compliance Counsel, United States Department of Justice, 6 Harvard Business Law Journal 69 (2016)

The Flood Tide of Cyberfraud, United States Attorneys’ Bulletin, March 2014, at 1

Iago’s Net: Notes for an International Legal Regime to Combat Identity-Related Crime, 42 Georgetown Journal of International Law 923 (2011)

Foreground and Background in Cybercrime: A Reply to Pinguelo and Muller, 16 Virginia Journal of Law and Technology 361 (2011)

Identity Theft: The Scope of the Problem, United States Attorneys’ Bulletin, March 2008, at 1

The top 10 e-commerce frauds and how to respond, 67 RCMP Gazette 20 (2005)

The compleat cyber-angler: a guide to phishing, Computer Fraud & Security, January 2005, at 4

Operation Web Snare: law enforcement networking against cyberfraud, Computer Fraud & Security, November 2004, at 16

Sentencing Guidelines for Copyright Pirates in the United States and the Hong Kong Special Administrative Region: A Comparative Perspective, 26 Fordham International Law Journal 315 (2003)

Computer and Internet Fraud: A Risk Identification Overview, Computer Fraud & Security, June 2003, at 6

ID theft: Authentication not enough, ZD, September 23, 2002

Identity theft: Fact and fiction, C/Net, September 18, 2002

‘Sweeping’ Up After Identity Theft, osOpinion, August 9, 2002

Prosecuting Offenses Under the Access Device Statute (18 U.S.C. § 1029), United States Attorneys’ Bulletin, November 2001, at 30

Making a Federal Case of Identity Theft, 11 Intersec 238 (July/August 2001)

The Rising Tide of Internet Fraud, United States Attorneys’ Bulletin, May 2001, at 6

Don’t Look Now, 9 George Mason Law Review 289 (2000)

Cyberspace and the “Devil’s Hatband”, 24 Seattle University Law Review 577 (2000)

Fraud Busters: The Attorney General’s Fraud Prevention Initiative, Journal of Public Inquiry, Fall/Winter 1999, at 15

(with Robert E. Hauberg, Jr.) Convicting the Bank Fraud Defendant, Criminal Justice, Fall 1991, at 2

“Consistency Is All I Ask”: An Exegesis of Section 6486 of the Anti-Drug Abuse Amendments Act of 1986, 41 Administrative Law Review 415 (1989)

Hue and Cry in the Counting-House: Some Observations on the Bank Secrecy Act, 37 Catholic University Law Review 465 (1988)

Book Chapters

Investigating complex crime, in Criminological Approaches to International Criminal Law (Ilias Bantekas and Emmanouela Mylonaki eds.) (Cambridge University Press, 2014)

An Overview of Worldwide Cybercrime Trends, 2013-14, in 1 Cybercrime & Security §4:7 (Thomson Reuters, 2014-2018)

Foreign Investment and United States Criminal Law, in Manual of Foreign Investment in the United States (Shepard’s/McGraw-Hill, rev. ed. 1993)

(with J. Eugene Marans) Foreign Direct Investment in United States Energy Resources, in Manual of Foreign Investment in the United States (Shepard’s/McGraw-Hill, rev. ed. 1993)

The Landscape of Federal Crimes Affecting Financial Institutions: A Tour d’Horizon, in Litigating For and Against the FDIC and the RTC (Practising Law Institute 1992)

Book Reviews

Judith M.T. Addis, Crème de Crime: Techniques for Interviewing White-Collar Criminals (1988), 18 University of Baltimore Law Review 635 (1989)

Benedict Vibe Christensen, Switzerland’s Role as an International Financial Center (1986), 10 University of Pennsylvania Journal of International Business Law 251 (1988)

A. Peter Mutharika, The Alien under American Law, Volume I, 17 Texas International Law Journal 123 (1982)

Gerard Smith, Doubletalk: The Story of the First Strategic Arms Limitation Talks (1980), 21 Columbia Journal of Transnational Law 219 (1982)

Frederic M. Scherer, Industrial Market Structure and Economic Performance (2d edition 1980), 1981 Arizona State Law Journal 355 (1981)


The Social Psychology of Corruption, Paper for OECD Integrity Forum, April 19-20, 2016

The Social Psychology of Computer Viruses and Worms, Paper Presented at INET 2002, Crystal Gateway Marriott, Crystal City, Virginia, June 21, 2002

The “Social Engineering” of Internet Fraud, Paper for INET ’99, June 22-25, San Jose, California


Dipping Through Geometries (July 2018- )

The Financial Conduct Authority’s Challenge to Challenger Banks, Oxford Business Law Blog, May 2, 2022

FinCEN and OCC Assess $140 Million in Civil Penalties Against USAA Federal Savings Bank for Failure to Implement and Maintain Anti-Money Laundering Program, Compliance & Enforcement, April 26, 2022

Hong Kong Securities and Futures Commission Imposes $45 Million Fine on Citigroup Global Markets Asia for “Pervasive Dishonest Behaviour” on Trading Desks, Compliance & Enforcement, February 25, 2022

France’s Conseil d’Etat Upholds €100 Million Fine Against Google for Advertising Cookie-Related Data Protection Violations, International Enforcement Law Reporter Blog, February 21, 2022

United Kingdom Solicitors Regulation Authority Imposes £232,500 Financial Penalty on Law Firm for Money Laundering Regulations Violations, Compliance & Enforcement, February 11, 2022

UK Financial Conduct Authority Imposes £264.8 Million Criminal Penalty on National Westminster Bank for Serious Anti-Money Laundering Violations, Compliance & Enforcement, January 6, 2022

European Commission Fines Five Global Banks €344 Million for Collusion in Forex Spot Trading, Oxford Business Law Blog, December 17, 2021

United States v. Bescond: The Second Circuit Construes the Fugitive Disentitlement Doctrine in a Corporate Criminal Investigation, Compliance & Enforcement, September 27, 2021

FinCEN Issues First AML/CFT Policy Priorities, Compliance & Enforcement, July 6, 2021

The Biden Administration National Security Study Memorandum on Corruption: Implications for the UK, Oxford Business Law Blog, July 1, 2021

Is There a Role for Machine Learning in Anti-Corruption Risk and Compliance?, Oxford Business Law Blog, June 16, 2021

Bank Julius Baer Agrees to Pay More Than $79 Million for Role in FIFA Money Laundering, Compliance & Enforcement, June 2, 2021

Central Bank of Ireland Fines Ulster Bank Ireland €37.7 Million for Serious Customer Mistreatment, Compliance & Enforcement, May 3, 2021

Should Companies Use Machine Learning for Their Anti-Corruption Programs?: The New Coalition for Integrity Guidance, Compliance & Enforcement, April 13, 2021

Ivory-Tower Money Laundering: Risks for Colleges and Universities, Compliance & Enforcement, March 11, 2021

Former IT Employee Sentenced to Prison for Damaging Company’s Computer Network, International Enforcement Law Reporter Blog, October 2, 2020

French Court Sentences Diacks to Prison in IAAF Corruption Case, International Enforcement Law Reporter Blog, September 24, 2020

FATF Issues Guidance on Cryptocurrency-Related Red Flags Indicative of Money Laundering and Terrorist Financing, Compliance and Enforcement, September 22, 2020

Using Artificial Intelligence to Study Corruption (I): Academic and Non-Governmental Organization Research, Center for the Study of Business Ethics, Regulation & Crime Directors Blog, September 9, 2020

Professional standards in police training: Unnecessary harm in use-of-force exercises, Trusted Policing, June 26, 2020

European Commission Announces Six-Point Action Plan on Money Laundering and Terrorist Financing, Compliance & Enforcement, June 5, 2020

Swedish and Estonian Regulatory Actions Against Swedbank for Anti-Money Laundering Compliance Failures, Compliance & Enforcement, May 21, 2020

FINMA Annual Report Indicates Decline in Enforcement, Highlights Money Laundering Risk Factors, Compliance & Enforcement, April 21, 2020

FINMA Imposes Measures and Sanctions on Julius Baer for Serious Anti-Money Laundering Failings, Compliance & Enforcement, March 13, 2020

Yeatts v. Zimmer Biomet Holdings, Inc.: Reconciling Compliance Obligations With Defamation Law, Anti-Corruption Report, February 5, 2020

Dutch Cabinet Ministers Present Action Plan on Money Laundering to Dutch Legislators, Compliance & Enforcement, July 23, 2019

“They Wanted the Barrels”: A Case Study in Behavioral Influences on Corporate-Compliance Decisionmaking, Compliance & Enforcement, February 28, 2019

Giving Cybersecurity the “Cassandra Treatment”, Compliance and Ethics Blog, February 25, 2019

Is A European Anti-Corruption Prosecutor Needed?, Compliance & Enforcement, February 15, 2019

Compliance salaries rise. Is that a good thing?, FCPA Blog, February 11, 2019

Sorry, but corruption can be measured, FCPA Blog, February 7, 2019

Section 7 of the United Kingdom Bribery Act 2010 and the “Fair Warning Principle”, Compliance & Enforcement, February 13, 2018

Public Testimony

Statement on Telemarketing Fraud Before the United States Sentencing Commission, February 10, 1998