Philip Urofsky

Philip Urofsky

Shearman & Sterling LLP

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Securities Enforcement 2014 Mid-Year Review

While not nearly as transformative and dramatic as the first half of 2013 and the early days of Chair Mary Jo White and Director of Enforcement Andrew Ceresney, the first six months of 2014 was just as busy and productive...more

8/1/2014 - Citigroup Enforcement Enforcement Actions Judge Rakoff Neither Admit Nor Deny Settlements SEC Settlement

Shearman & Sterling's Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA)/FCPA Digest

In this issue: - Recent Trends and Patterns in FCPA Enforcement - Recent Trends and Patterns in FCPA Enforcement Enforcement - Actions and Strategies - Statistics - Types of Settlements...more

7/22/2014 - Chief Compliance Officers Compliance Enforcement Ethics FCPA

Sanctions Round-Up: Second Quarter 2014

In this issue: - US Authorities End Quarter Full of Enforcement Actions with $8.9 Billion BNP Settlement - US and EU Make Numerous Ukraine-Related Designations as Separatist Aggression Continues - US...more

7/10/2014 - Enforcement Enforcement Actions EU Human Rights Russia Sanctions Ukraine

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

Sanctions Round-Up: First Quarter 2014

In this edition: - Implementation of the Joint Plan of Action with Iran - Additional US Iran-Related Sanctions and Licenses - OFAC Civil Settlements - US and EU Sanctions in Response to the Situation in...more

4/4/2014 - EU Iran Sanctions Joint Plan of Action OFAC Sanctions Ukraine

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

SEC Enforcement Year in Review - 2013

Marked by leadership changes, high-profile trials, and shifting priorities, 2013 was a turning point for the Enforcement Division of the Securities and Exchange Commission (the “SEC” or the “Commission”). While the results of...more

1/9/2014 - Accounting Fraud Auditors Bribery Broker-Dealer China Deferred Prosecution Agreements Disclosure Dodd-Frank Enforcement Actions FCPA FIRREA Injunctions Insider Trading Investment Adviser Mary Jo White Municipal Securities Issuers Neither Admit Nor Deny Settlements SEC Securities Fraud Statute of Limitations Whistleblowers

Sanctions Round-Up: Fourth Quarter 2013

As 2013 drew to a close, a potentially groundbreaking agreement was reached with Iran regarding its nuclear program, leading to much speculation about how certain sanctions might be suspended, and under what conditions. While...more

1/7/2014 - Iran Sanctions National Security OFAC Sanctions U.N. Security Council United Nations

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

Iran Notices Update: SEC-Registered Issuers Continue to Adapt to Their New Normal

It has been over eight months since SEC-registered issuers began making mandatory disclosures of business activities in or with Iran. During that period, issuers have filed over 400 Iran Notices with the SEC, including...more

11/5/2013 - Iran Iran Sanctions OFAC SEC

Sanctions Round-Up: Third Quarter 2013

In this edition: - Iranian Sanctions Eased to Allow Additional Humanitarian Exports and Activities - New Iranian Sanctions Designations Announced - Significant Reduction Waivers Extended - Global...more

10/9/2013 - Enforcement Actions EU Iran Iran Sanctions Middle East Sanctions

Sanctions Round-Up: Second Quarter 2013

In this issue: - The Iran Freedom and Counter-Proliferation Act of 2012 - E.O. 13645, issued June 3, 2013 - Enforcement Against Foreign Sanctions Evaders - Enforcement Against Human Rights...more

7/15/2013 - Department of State Foreign Banks Foreign Policy Iran Sanctions NDAA OFAC Sanctions Settlement

The Ralph Lauren FCPA Case: Are There Any Limits to Parent Corporation Liability?

Much of the coverage of the recent Foreign Corrupt Practices Act case against Ralph Lauren Corp. (RLC) focused on the fact that both the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) awarded it...more

6/6/2013 - Disgorgement DOJ FCPA Fines Liability Non-Prosecution Agreements OECD Parent Corporation Ralph Lauren SEC Strict Liability

Sanctions Round-Up: First Quarter 2013

In this issue: - OFAC Releases New SDN Search Tool - Additional Provisions Targeting Iran Go Into Effect - OFAC Continues to Target Foreign Sanctions Evaders - Section 219 Disclosures Begin - Burma...more

4/22/2013 - Iran Sanctions Iran Threat Reduction and Syria Human Rights Act NDAA OFAC

What’s Going On – Over A Month Of Section 219 Disclosures Under The Iran Threat Reduction And Syria Human Rights Act Of 2012

Section 219 (codified as Section 13(r) of the Securities Exchange Act) has been in effect for six weeks. During this time, more than 100 SEC-registered reporting issuers have made required disclosures regarding their Iran or...more

3/20/2013 - Iran Threat Reduction and Syria Human Rights Act Reporting Requirements

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