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The Gloves are Off: U.S. Sanctions Block Aggressors in Crimea

In response to Russia’s military presence in the Crimean region of Ukraine, President Obama issued an Executive Order (“EO”) on March 6, 2014, authorizing the blocking of property of individuals and entities involved in the...more

3/11/2014 - Executive Orders Financial Crimes Foreign Banks Russia Sanctions U.S. Treasury Ukraine

Dodd-Frank Whistleblower Protection: For America Only

The U.S. District Court for the Southern District of New York has held that the whistleblower protection provisions of the Dodd-Frank Act do not apply outside the United States, even where the employee alleged he was...more

11/14/2013 - Anti-Retaliation Provisions Dodd-Frank Extraterritoriality Rules FCPA Whistleblower Protection Policies Whistleblowers

Politics and Consequences: An Update on U.S. Sanctions Against Iran

Since Hassan Rouhani’s election to the Iranian presidency, some U.S. leaders have expressed interest in diplomatic talks with Iran. It is currently unclear whether any such talks will ever occur, or on what terms. In the...more

10/11/2013 - FFI Iran Sanctions Medical Devices Middle East OFAC Prescription Drugs

ECR Series Episode VI: The One With Ewoks (And New Rules On Satellites)

This fall, the U.S. Government will finish considering public comments on its draft revision of U.S. Munitions List Category XV, which covers “Spacecraft Systems and Related Articles.” By the end of 2013 (unless delayed by...more

10/10/2013 - Commerce Control List NDAA Satellites U.S. Commerce Department US Munitions List

A Rising Voice on FCPA Compliance: The Court

One FCPA compliance topic we are often asked about by clients is how government investigations start. The U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have developed a number of mechanisms...more

6/11/2013 - Compliance DOJ FCPA IBM Investigations SEC

Streamlining the System: More Baby Steps Toward Reducing Export Compliance Burdens

Since 2011, President Barack Obama’s administration has actively pursued export control reform designed to reduce the regulatory burdens on U.S. companies and enhance U.S. national security (as reported here). On March 7,...more

4/3/2013 - Barack Obama Commerce Control List Compliance Executive Orders Export Administration Regulations Exports ITAR US Munitions List

New Law To Assess Iranian Activities in the Americas

The U.S. Government has taken yet another step to counter the threat of Iran-sponsored terrorism, this time focusing on Iran’s direct activities in the Western Hemisphere. On December 28, 2012, President Barack Obama signed...more

2/21/2013 - Countering Iran in the Western Hemisphere Act Department of State Terrorist Threats

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

What’s In the New FCPA Resource Guide: Some Welcome Clarity and Unexpected Muddling

Much has been said about what is missing from the new FCPA Resource Guide (the Guide) published by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). Here, we consider instead the areas in...more

12/6/2012 - Compliance DOJ FCPA FCPA Resource Guide 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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