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Tryin’ to Make a Dollar out of Fifteen Cents: The Diebold FCPA Settlement Explains What Officials Did on Their Vacation

Vacation is great, but it can involve a great deal of planning. And, paradoxically, leisure travel can involve more planning than traveling for business. That travel-related work stands out as a centerpiece of the October...more

11/15/2013 - Bribery Deferred Prosecution Agreements Diebold Inc DOJ Enforcement Actions FCPA SEC

Fixing a Broken Brokering Definition: DDTC Eases ITAR’s Regulatory Burden for Brokers and Brokering Activities

On August 26, 2013, in yet another move geared toward streamlining the U.S. export control regulatory landscape, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) published its long-awaited interim...more

9/6/2013 - Broker-Dealer Brokers Department of State Exports ITAR US Munitions List

Census Changes Foreign Trade Regulations: New Filing Requirements

On Thursday, March 14, the Census Bureau published a final rule (available here) implementing changes to the Foreign Trade Regulations (FTR), 15 C.F.R. Part 30. The final rule includes long-awaited revisions to the...more

4/3/2013 - Automated Export System Census Bureau Exports Foreign Trade Regulations Imports Option 4 Filing

New Law Expands Scope of Iran Sanctions In New Ways

As the new year brings in a new term for the Obama Administration, the pace of Iran sanctions shows no sign of slowing. As we reported in October and November, Washington’s commitment to denying Iran the ability to advance...more

2/15/2013 - Coal FFI IFCPA Iran Sanctions Metals NDAA OFAC Reinsurance SDN List Shipbuilding Shipping Software Underwriting

No Knowledge, but Hints of Omissions in the Allianz FCPA Settlement

On December 17, 2012, the Securities and Exchange Commission (“SEC”) announced a settlement under the U.S. Foreign Corrupt Practices Act (“FCPA”) with Allianz SE (“Allianz”), the insurance company based in Germany, resulting...more

1/10/2013 - Allianz Books & Records Bribery Compliance Disgorgement FCPA FCPA Resource Guide Penalties SEC

Iranian Transactions and Sanctions Regulations Impose New Restrictions on U.S. Business in Iran

As we reported last month, the Obama administration continues to display a commitment to increasingly tough sanctions against Iran and its trading partners. Over the past few weeks, the U.S. Department of the Treasury, Office...more

11/20/2012

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