Compliance & Ethics

For years, pyramid schemes were thought of as a relic of the 1990s. According to Poland’s competition authority, they never really went away. They just learned new language, new platforms, and new disguises. On December 30, 2025, the President of UOKiK announced more than $6 million (over PLN 24 million) in combined fines against two U.S.-based companies, iGenius and International Markets Live, concluding that both operated prohibited pyramid-type incentive schemes.

The Korea Financial Intelligence Unit (Korea Financial Intelligence Unit) recently held the first meeting of a new taskforce tasked with revisiting the Act on Reporting and Using Specified Financial Transaction Information. While the meeting itself was procedural, the mandate behind it is anything but. The taskforce is meant to modernize Korea’s AML framework, sharpen responses to cross-border crime and large-scale financial fraud, and prepare the ground for South Korea’s next mutual evaluation by the Financial Action Task Force in 2028.

The European Banking Authority has quietly but meaningfully updated the rulebook that governs how EU supervisors share sensitive information with their counterparts outside the bloc. In revised Guidelines published on December 22, 2025, the EBA strengthened its framework for assessing whether third-country confidentiality and professional secrecy regimes meet EU standards, an essential precondition for effective cross-border supervisory cooperation.

The Federal Trade Commission is sending a message to companies that play fast and loose with online reviews. FTC staff issued warning letters to 10 companies, flagging potential violations of the agency’s relatively new Consumer Review Rule, which targets fake, misleading, and manipulated product reviews.

Italy’s competition watchdog has hit Ryanair with a €255.76 million fine, jointly and severally with its parent Ryanair Holdings plc, after concluding that the airline abused its dominant position in the market for passenger air transport services to and from Italy.

The U.S. Treasury is leaning harder into data, technology, and coordination as it steps up efforts to disrupt money laundering tied to organized crime and cross-border networks. This week, the Financial Crimes Enforcement Network announced a sweeping, data-driven operation focused on money services businesses operating along the southwest border, which is an initiative that shows how aggressively the department is now using financial intelligence to drive enforcement.

Foreign bribery cases rarely begin with a single, obvious act. They tend to surface through patterns, unusual secrecy, opaque ownership structures, and contracts that don’t quite add up. That reality is at the heart of new guidance released this week by the Serious Fraud Office and its Five Eyes law-enforcement partners.