Paula Howell Anderson

Paula Howell Anderson

Shearman & Sterling LLP

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Gifts of Travel and Luxury Watches to Saudi Officials Not Mere 'Icing on the Cake' for FCPA Charges

Improper Gifts Alone, Without Cash Bribes, Serve as Basis for SEC’s Latest FCPA Enforcement Action - Earlier this week, the SEC announced fines for two former defense contractor employees for FCPA violations relating...more

11/21/2014 - Bribery Conditional Gifts Enforcement Actions FCPA Foreign Official Popular Saudi Arabia SEC

SEC Settlement with Layne Christensen Raises New Questions on the Government’s Understanding of the Business Nexus Element of the...

Last week the SEC settled charges against Layne Christensen for various violations of the FCPA. While a relatively unremarkable case at first glance, the SEC’s charges against Layne Christensen reflect a troubling approach by...more

11/5/2014 - Cease and Desist Orders Consent Order Construction Industry FCPA Layne Christensen Co SEC Subsidiaries

So You Want to See Messi, Neymar, Ronaldo, and Xavi: Brazil Issues Directive Barring Government Officials From Receiving World Cup...

Earlier today, the Office of the Comptroller General in Brazil, Controladoria-Geral da União (“CGU”), issued a sweeping directive barring government officials from accepting offers to attend or participate in the upcoming...more

6/3/2014 - Brazil Compliance FCPA Government Officials Public Officials UK UK Bribery Act World Cup

OFAC Settles Civil Enforcement Action with Dutch Company for Alleged Violations of US Trade Embargo on Cuba

The US Treasury’s Office of Foreign Assets Control (OFAC) and Carlson Wagonlit Travel B.V. (CWT), a Netherlands-based company, have agreed to settle violations of the Cuban Assets Control Regulations (CACRs) dating back to as...more

4/25/2014 - EU OFAC Settlement U.S. Treasury

A Potential Fork in the Road: US and EU Sanctions Relating to the Ukrainian Crisis

Both the United States and the European Union have issued calibrated Ukraine-related sanctions as a direct response to the recent political upheaval in Ukraine. Although both US and EU sanctions target certain persons for...more

4/2/2014 - EU Russia Sanctions Ukraine

January 2014 Recent Trends and Patterns in Foreign Corrupt Practices Act (FCPA) - Enforcement report only

In this issue: - Enforcement Actions and Strategies - Perennial Statutory Issues - Unusual Developments - Compliance Guidance - Private Litigation - Enforcement in the United...more

1/7/2014 - Compliance Enforcement Enforcement Actions FCPA OECD UK Voluntary Disclosure

Opportunities and Pitfalls of Proposed Easing of Iran Sanctions

After years of fitful progress and failure, Iran and the five permanent members of the United Nations Security Council (China, France, Russia, the United Kingdom, and the United States) and Germany (collectively the “P5+1”)...more

12/6/2013 - Iran Sanctions U.N. Security Council United Nations

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