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Cuba Sanctions Relief: Baby Steps Today, But What About Tomorrow?

For more than 50 years, an embargo and related sanctions regime has restricted U.S. businesses and individuals from virtually all economic activity involving Cuba or its nationals. This regime was implemented through a...more

On the application of personal sanctions by Ukrainian banks

By a new Resolution of the National Bank of Ukraine (the "NBU") No. 654 dated 1 October 2015 (the "Resolution") a procedure on application of sanctions was introduced....more

Recent Settlements Signal Increased Political Law Enforcement by Government Officials

The U.S. government reached settlements with two federal lobbyist registrants recently in what appears to signal increased enforcement of political activity laws. On August 28, 2015, the U.S. Attorney’s Office for the...more

Iran Sanctions Relief: Opportunities and Challenges for US and EU Financial Institutions

Although US and EU sanctions targeting Iran are not likely to be lifted before early 2016, there are a number of issues which US and EU-based financial institutions should be aware of in preparation for sanctions relief as a...more

US revises Cuba sanctions regulations to further normalize trade with Cuba

On September 18, 2015, the US Department of Treasury and US Department of Commerce released significant revisions to the US embargo on Cuba, as set out in the Cuban Assets Control Regulations (CACR) and the Export...more

Checking In on Sanctions Enforcement

The Department of Treasury’s Office of Foreign Asset Control continues to ramp up sanctions enforcement. Even with the likely relaxation of the Iran and Cuba sanctions, OFAC has been continuing its aggressive enforcement...more

Prohibitions on Restrictions to Assignment of Receivables

Many businesses assign or charge their receivables in order to obtain finance, and in many cases, to improve cashflow. Following the financial crisis of 2008, alternatives to bank-led finance have been sought by businesses,...more

Cuba Sanctions Relief: The Knot Further Loosens

Effective September 21, the U.S. Department of Treasury amended its Cuban Assets Control Regulations (CACR), providing further Cuba sanctions relief. In a coordinated action, the U.S. Department of Commerce simultaneously...more

Iran Deal “Clears” Congress, But No Sanctions Relief Yet

On September 10, 2015, Senate Democrats in the U.S. Congress blocked a vote on a widely anticipated resolution to reject the Joint Comprehensive Plan of Action (“JCPOA”) regarding Iran’s nuclear program. On September 11, the...more

44 Senators Ask SEC to Require Disclosure of Political Contributions

In this letter 44 senators called on SEC Chair Mary Jo White to act on a rulemaking petition that would require companies to disclose their political spending. The letter was referring to Petition for Rulemaking, File No....more

DC Circuit Tosses Republican’s Challenge to Adviser Pay-to-Play Rule

The District of Columbia Circuit Court of Appeals Tuesday rejected a challenge to the SEC’s investment-adviser pay-to-play rule, holding that two state Republican Party organizations filed it almost four years too late....more

TN Republican Party Loses Challenge to Adviser Pay-to-Play Rule

The District of Columbia Circuit Court of Appeals Tuesday rejected a challenge to the SEC’s investment-adviser pay-to-play rule, holding that New York and Tennessee Republican-Party organizations filed it almost four years...more

Special Session Ends with Handful of Noteworthy Tax Bills, Predictions for Next Special Session

The first Special Session of 2015 ended on Tuesday, August 11, without accomplishing the primary objective of passing a General Fund budget for the 2015-2016 fiscal year. The Governor’s “call” for the special session included...more

International Trade Alert: Business Opportunities in Iran - Are You Properly Equipped to Join the Race?

As European business gears up for a post-sanctions environment and the strengthening of relationships in an economically significant emerging market, many clients continue to face mixed messages with regards to what they can...more

First EU Steps to Prepare for Sanctions Relief under Iran Deal

On July 31, 2015, the European Union (EU) adopted the first measures to prepare for the implementing of the Joint Comprehensive Plan of Action (JCPOA) with Iran by allowing EU Member States to authorise certain activities...more

Illinois Legislature Deals Deathblow to Dina

Recently, in a rare display of bipartisanship, the Illinois House and Senate passed—almost unanimously—an amendment to the Illinois Residential Mortgage License Act, 205 ILCS 635/1-1 et al. (IRMLA). On July 23, 2015, Governor...more

US Issues Crimea Sanctions Advisory, Designates Additional Russian and Ukrainian Individuals and Entities

On July 30, 2015, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Crimea Sanctions Advisory, identified certain subsidiaries of entities included on the Sectoral Sanctions Identifications...more

Additional U.S. Sanctions Imposed on Russian and Ukrainian Persons, But No Significant Escalation

On July 30, 2015, the U.S. Government added dozens of Russian and Ukrainian individuals and entities to the Ukraine-related sanctions lists.1 U.S. officials have stated that these new additions are not an escalation of U.S....more

The SEC Considers Updating the Accredited Investor Definition: A Discussion of Status, SEC Advisory Committee Recommendations,...

The accredited investor (AI) definition is an extremely important component of the private placement market. A significant amount of capital is raised using Regulation D, and accredited investors participated in 89 percent of...more

Looking Ahead to Lifting Sanctions Against Iran - Key takeaways from the July 22, 2015 conference call

On July 22, 2015, Shearman & Sterling hosted a client call on Iran sanctions led by Dan Newcomb, Anthony Patten, Barney Reynolds and James Campbell to examine the impact of this historic agreement and discuss how companies...more

Gov. Christie’s Cuts in N.J.’s Mandatory Public Pension Funding Found to be Legal

A recent study estimated that state public pension plans are underfunded by $4.7 trillion (yes, that’s a “T”). Ten states have plans in which less than 30-percent of benefit obligations are funded, and only three states have...more

Implementation Day: Do the Rules Let You Play in the New Ballgame for Business in Iran?

After a twelve-year standoff that saw the United States and Europe ratchet up sanctions pressure on Iran, a diplomatic breakthrough has been reached. But robust trade between Iran and the West will not arise immediately,...more

Alabama 2015 Regular Session Legislative Summary: June 2015

The Alabama Senate adjourned sine die on Thursday, June 4, and the Alabama House of Representatives met for their last day on Thursday, June 11. Although the legislature passed a record-setting, $6 billion Education Trust...more

Pay-to-Play Implications of Governor Chris Christie’s Presidential Run

After today’s announcement, New Jersey Governor Chris Christie joins a long list of 2016 presidential candidates, from both parties. But Christie’s position as a sitting governor means that he is subject to different...more

N.J. Supreme Court Finds Chapter 78 Did Not Create an Enforceable Contract Right

In Burgos v. State of New Jersey, the New Jersey Supreme Court held that the 2011 pension and health benefit reform statute, known as Chapter 78, did not create an enforceable contract that was binding on the State to make...more

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