Thomas Bogle

Thomas Bogle

Dechert LLP

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U.S. Government Takes Steps to Further Ease Restrictions on Cuba

U.S. Commerce and Treasury Department measures intended to further ease existing export and sanctions restrictions regarding Cuba took effect on September 21, 2015. These amendments to the Cuban Assets Control Regulations...more

9/28/2015 - Cuba Cuban Assets Control Regulations (CACR) Export Administration Regulations Export Controls Internet Telecommunications Trade Restrictions U.S. Commerce Department U.S. Treasury

U.S. Proposes to Subject Non-U.S. SEC Registered Investment Advisers to Anti-Money Laundering Rules

The United States is proposing rules that, for the first time, would subject investment advisers registered or required to be registered (RIAs) with the U.S. Securities and Exchange Commission (SEC) under the Investment...more

9/24/2015 - Anti-Money Laundering Bank Secrecy Act FinCEN Non-US Entities Registered Investment Advisors SEC Suspicious Activity Reports

FinCEN Proposes Anti-Money Laundering Regulation for Investment Advisers

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking on August 25, 2015,1 pertaining to all investment advisers registered or required to be registered...more

9/23/2015 - Anti-Money Laundering Bank Secrecy Act Compliance FinCEN Investment Adviser NPRM Recordkeeping Requirements Registered Investment Advisors Suspicious Activity Reports U.S. Treasury

US and Cuba Seek to Normalize Relations; US to Ease Certain Restrictions

President Obama announced on December 17, 2014 that the United States and Cuba will open talks seeking to restore full diplomatic relations, and that the United States will be taking a number of steps to ease restrictions in...more

12/18/2014 - Barack Obama Cuba Foreign Relations

New Law Significantly Expands Legal Basis for US Sanctions Against Russia

On 16 December 2014, President Obama announced that he will sign the Ukraine Freedom Support Act of 2014 (hereinafter the “Act”) into law. As discussed in our update dated 12 December 2014, the Act represents a potentially...more

12/18/2014 - Banking Sector Defense Sector Energy Sector FFI New Legislation OFAC Russia Sanctions Ukraine

Novel U.S. and EU Sanctions Targeting Russian Financing Activities Raise Unique Compliance Considerations for Global Financial...

Since March 2014, the United States and European Union have imposed multiple rounds of sanctions restricting certain activities with Russian and Ukrainian individuals and companies as a result of the ongoing crisis in...more

10/16/2014 - EU Financial Instruments Russia Sanctions SSI List Ukraine

US and EU Impose Additional Sanctions on Russia

The United States and European Union implemented new sanctions against Russia on 12 September 2014 as a result of the ongoing crisis in Ukraine. While the new US and EU measures share many similarities, companies subject to...more

9/15/2014 - EU Russia Sanctions Ukraine

Additional EU Sanctions Imposed on Russia

The European Union announced its intention to adopt a broad package of trade and economic sanctions against Russia, targeting access to EU capital markets, defence exports, energy related equipment and technology and...more

8/1/2014 - Capital Markets Energy Sector EU Export Controls Exports Financial Institutions Oil & Gas Russia Sanctions

Additional US and EU Sanctions Imposed on Russia and the Russian Government Reaction

On July 16, 2014, the U.S. Government imposed additional sanctions against Russian and Ukrainian individuals and companies as a result of the ongoing crisis in Eastern Ukraine. In addition to adding five individuals and 11...more

7/18/2014 - EU Russia Sanctions US

Latest Round of US and EU sanctions on Russia and the Russian Government Reaction

In response to recent events in Ukraine, the United States and European Union imposed yet another round of sanctions this week. In response, Russia is considering a number of countermeasures that may affect U.S. and EU...more

4/30/2014 - BIS EU Executive Orders Exports Licenses OFAC Russia Sanctions Ukraine Visas

US, EU and Russia Swap Sanctions

President Obama issued yet another new Executive Order (E.O.) blocking property of additional Russian persons the U.S. Government holds responsible for the situation in Ukraine on 20 March 2014. For its part, on 21 March...more

3/26/2014 - EU Foreign Policy Russia Sanctions Ukraine

US and EU Impose Additional Sanctions on Russia

The United States and the European Union imposed new targeted sanctions on Russian and Ukrainian political figures viewed as responsible for undermining Ukrainian sovereignty on 17 March 2014. Both the EU and U.S. have made...more

3/26/2014 - EU Foreign Policy Russia Sanctions Ukraine

Two Non-U.S. Banks Agree to Pay Penalties Totaling $160 Million for Violations of U.S. Sanctions Laws Resulting from Omnibus...

Recent enforcement actions brought by the U.S. Government against non-U.S. banks for violations of U.S. sanctions laws demonstrate the need for financial institutions, particularly those that act as custodians or financial...more

1/30/2014 - Anti-Money Laundering Bank Secrecy Act Banks Compliance FinCEN Foreign Banks Iran ITSR OFAC Sanctions U.S. Treasury

FSB and IOSCO to Consider Standards for Treating Investment Funds and Asset Managers as Global Systemically Important Financial...

The Financial Stability Board (FSB), in consultation with the International Organization of Securities Commissions (IOSCO), issued “Assessment Methodologies for Identifying Non-Bank Non-Insurer Global Systemically Important...more

1/17/2014 - Banking Sector Broker-Dealer Financial Companies FSB Global Economy Hedge Funds Investment Funds IOSCO Nonbank Firms Securities

Former Morgan Keegan Directors Settle Valuation Case

The U.S. Securities and Exchange Commission issued a cease and desist order on June 13, 2013 (the “Order”) against former members of the boards of directors (the “RMK Directors” or the “RMK Boards”) of five Regions Morgan...more

7/3/2013 - Board of Directors Business Assets Directors Enforcement Investment Companies Investment Company Act of 1940 SEC Settlement Subprime Mortgages Valuation

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