Last month, the U.S. Department of Justice (DOJ) announced that it would not charge MilliporeSigma, a life sciences company, even though one of its employees falsified export documents. The DOJ declined to prosecute...more
On October 4, 2023, Deputy Attorney General (AG) Lisa Monaco announced the U.S. Department of Justice’s (DOJ’s) new Mergers & Acquisitions Safe Harbor Policy for acquirers that uncover wrongdoing at a target company. Deputy...more
As the war in Ukraine rages on, recent advisories from financial crime agencies in the United States and the United Kingdom indicate heightened scrutiny on financial activity of Russian individuals and entities, including...more
1/20/2023
/ Economic Sanctions ,
Financial Institutions ,
Financial Services Industry ,
Financial Stimulus ,
Foreign Investment ,
Foreign Nationals ,
Foreign Policy ,
Popular ,
Russia ,
UK ,
United States
On November 28, 2022, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced that Payward, Inc. d/b/a Kraken, a U.S.-based cryptocurrency exchange, agreed to pay $362,158.70 to settle charges relating to its...more
On October 11, 2022, the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced settlements with Bittrex Inc. (Bittrex). The settlements arise from violations of...more
10/19/2022
/ Anti-Money Laundering ,
Crypto Exchanges ,
Cryptoassets ,
Cryptocurrency ,
Economic Sanctions ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanctions
On September 30, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published its final regulations on Beneficial Ownership Information (BOI) Reporting Requirements. The regulations...more
On September 15, 2022, Deputy Attorney General of the Department of Justice (DOJ) Lisa Monaco announced pivotal new guidance about the DOJ’s corporate criminal enforcement efforts. Her speech, accompanied by a more...more
On July 20, 2022, the Secretary of State for the Department for Business, Energy, and Industrial Strategy (BEIS) within the UK government published a final order blocking a proposed licensing arrangement between the...more
Many public companies are beginning preparations for filing quarterly reports on Form 10-Q for the second quarter of calendar 2022. As they do so, they should review and consider the U.S. Securities and Exchange Commission...more
On June 16, 2022, the Department for Business, Energy, and Industrial Strategy (BEIS) published its first annual report regarding the National Security and Investment Act 2021 (the NSI Act). The report solely covers the...more
On February 24, 2022, the United States, in coordination with the European Union, the United Kingdom, Canada, Australia, Japan, and other allies, took further action against Russia and Belarus in response to Russia's invasion...more
New Sanctions Also Authorized on Russian Financial Institutions, Elites, and Sovereign Debt, with UK and EU Sanctions to Follow -
The Biden administration announced measures this week in response to the Russian...more
In December 2021, the Court of Justice of the European Union (the CJEU) published a judgment interpreting the European Union's Blocking Regulation....more
In January 2021, President Biden was sworn into office and for the first time in a decade, Democrats assumed control of both chambers of Congress. Notwithstanding these changes, the U.S. government has continued to rely on...more
1/14/2022
/ Belarus ,
Belarus Sanctions ,
Biden Administration ,
China ,
Corporate Counsel ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
Virtual Currency
On December 8, 2021, the Treasury Department's Financial Crimes Enforcement Network (FinCEN) published its proposed regulations on beneficial ownership information (BOI) reporting requirements. These FinCEN regulations will...more
The United Kingdom's National Security and Investment Act (the NSI Act) is now fully in force. First proposed in 2016, the NSI Act creates a stand-alone regime that authorizes the UK government to consider and address the...more
1/4/2022
/ Acquisitions ,
Corporate Counsel ,
Critical Infrastructure Sectors ,
Defense Sector ,
Foreign Acquisitions ,
Foreign Investment ,
Investors ,
Mergers ,
National Security ,
National Security Review Proceedings ,
Public Interest ,
UK
The U.S. Treasury Department's Office of Foreign Assets Control (OFAC) published new guidance last week for the virtual currency industry. While OFAC's economic sanctions compliance obligations apply to all U.S. persons, the...more
The United Kingdom's National Security and Investment Act (NSI Act) is scheduled to come fully into force on January 4, 2022. The NSI Act will create a new framework for the UK government to review so-called "trigger events,"...more