Building on the “first tranche” of sanctions announced on February 22, 2022 described in our prior alert, the United States, the EU, the UK, and their allies have imposed (or announced the imposition of) additional...more
3/1/2022
/ Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Financial Transactions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SWIFT ,
Ukraine ,
Virtual Currency
President Biden issued a new Executive Order 14024 (“E.O. 14024”) on April 15, 2021, expanding sanctions against Russia. E.O. 14024 authorizes, for the first time, U.S. sanctions against Russian technology companies and,...more
4/21/2021
/ Biden Administration ,
Crimea ,
Critical Infrastructure Sectors ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts
On December 13, 2019, the National Security Division (“NSD”) of the U.S. Department of Justice (“DOJ”) released a revised enforcement policy (“the Policy”) meant to encourage companies to voluntarily self-disclose potentially...more
12/23/2019
/ Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
FCPA Corporate Enforcement Policy (CEP) ,
FCPA Guidance ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Sanction Violations ,
Self-Disclosure Requirements ,
Voluntary Disclosure
Even today, most companies—even technology companies—do not think they have information that the U.S. Government wants or needs, particularly as it might relate to a national security investigation. The reality is that as...more
10/14/2016
/ Credit Reporting Agencies ,
ECPA ,
Electronic Communications ,
FBI ,
Financial Institutions ,
Information Requests ,
Internet Service Providers (ISPs) ,
National Security ,
National Security Letters (NSLs) ,
Patriot Act ,
Telecommunications ,
Terrorist Threats
The last four years has seen a trend of increased law enforcement and regulatory investigations into financial institutions for sanctions violations and anti-money laundering, or Bank Secrecy Act ("BSA"), compliance. The New...more