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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

Global Procurement Quarterly - Summer/Fall 2014

In This Issue: - Recent Trends in FCPA Enforcement – First Half of 2014 - Ukraine/Russia–Related Sanctions - New Executive Order Places Additional Reporting Obligations on Government Contractors and...more

Ratcheting up the Pressure: Reinforced Ukraine-related Sanctions on Russia

On September 12, 2014, the United States (“U.S.”) and European Union (“EU”) both announced expanded sanctions related to Russia and Ukraine. These measures seek to increase pressure on the Russian Government to stop...more

Test Your Knowledge on OFAC Sanctions

Global sanctions have shot up the scale of high risks to be prioritized by international companies and financial institutions, including real estate, corporate and trust service provider businesses. The battle against...more

D.C. Bill Ostensibly Lowers Tax on Capital Gains from QHTC Investments… But How?

On September 23, District of Columbia Council Chairman Mendelson introduced the Promoting Economic Growth and Job Creation Through Technology Act of 2014 (Bill 20-0945 , hereinafter the “Act”) at the request of Mayor Vincent...more

Levick Monthly - October 2014, Edition 15: Offshore Is Next Target For Environmentalists

In This Issue: - DIGITAL: COVER STORY Guest Commentary: Offshore is Next Target for Environmentalists - CRISIS How to Talk About ISIS Over Dinner - CORPORATE & REPUTATION Non-Lethal Weapons: The Ferugson...more

Reg A+ Debate Continues

The debate regarding state preemption for Tier 2 Regulation A+ offerings appears to continue. Late last week, a group of Congressmen sent a letter to SEC Chair White reaffirming their view that the SEC has authority to...more

Further Toughening of Canada’s Sanctions Against Russia

The initial round of economic sanctions imposed by the Canadian government in March 2014 in response to Russia’s military intervention in Crimea targeted certain former Ukrainian government officials and their family members...more

New House Bills Seek To Relax Some SEC Requirements And Help Reverse The Growth In Income Inequality

Hat tip to thecorporatecounsel.net blog for identifying these two new House bills. H.R. 5405, Promoting Job Creation and Reducing Small Business Burdens Act, is intended to relax some additional requirements for Emerging...more

New U.S. Restrictions on Russia: OFAC Guidance and Industry-Specific Sanctions

OFAC Expands the 50 Percent Rule - Last month, the Department of Treasury’s Office of Foreign Assets Control (OFAC) released new guidance related to entities owned or controlled by persons designated as a Specially...more

Sanctions on Russia Expanded Despite Tenuous Truce

On Friday , September 12th, while a tenuous truce between Ukraine and rebel forces showed signs of cracking and government officials continued to trade verbal jabs, the United States amped up pressure on Russia by expanding...more

U.S. Imposes Further Economic Sanctions Against Russia

On September 12, the United States implemented another round of economic sanctions against Russia in response to the continued crisis in eastern Ukraine. On September 11, U.S. President Barack Obama declared the U.S....more

Only in New York, New York

Conventional wisdom holds that campaign finance reform is elusive. At both the federal level and in many states, the pace of enactment tends to be measured in decades....more

OFAC Makes Important Update to Ownership/Control Guidance

On August 13, 2014, the Office of Foreign Assets Control (OFAC) issued new guidance on ownership/control for determining blocked parties. This represented the first significant update on this topic since February 14, 2008,...more

Russia Sanctions: Impact on Financial Institutions in the US, EU and Japan

New sanctions targeting Russia have been implemented in the US, EU and Japan. Although the consequences of breaching the sanctions are severe, navigating the rules is not straightforward. Transactions and business lines will...more

MSRB Proposal Extends Rule G-37 “Pay-to-Play” Prohibitions to Municipal Advisors

In its August 18 Regulatory Notice No. 2014-15, the Municipal Securities Rulemaking Board (“MSRB”) proposed amendments to Rule G-37 that would extend the long-standing “pay-to-play” prohibition’s reach to newly-registered...more

Permanent Injunction of Pennsylvania’s Prohibition against Establishment of Political Committees to Receive Contributions of...

On August 13, 2014, an order was issued by the U.S. District Court for the Middle District of Pennsylvania in the matter of General Majority PAC v. Carol Aichele permanently enjoining implementation and enforcement of...more

MSRB Seeks to Extend Pay-to-Play Rule to Municipal Advisors

The Municipal Securities Rulemaking Board, or MSRB, is requesting comment on draft amendments to Rule G-37, the MSRB’s pay-to-play rule for municipal securities dealers, that would extend the rule to municipal advisors....more

District Judge Permanently Enjoins PA Law that Prohibited Corporate Contributions to IE Committees

On Wednesday, U.S. District Judge William Caldwell permanently enjoined enforcement of Pennsylvania’s prohibition on campaign expenditures by banks, corporations or unincorporated associations (such as labor unions) as...more

SANCTIONS UPDATE - New Treasury Guidance on Aggregation of Ownership Interests

On August 13, the U.S. Department of the Treasury published revised guidance on the treatment of entities owned by persons whose property and interests in property are blocked under the Executive Orders and regulations...more

OFAC Issues Revised Guidance on Aggregation of Ownership Interests

On August 13, 2014, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued revised guidance with respect to the “50% Rule,” which established that an entity owned 50% or more, directly or indirectly, by a...more

The US sanctions against Russia – in an evolving context, key points for business

Starting in March of this year, the United States imposed economic sanctions in response to Russian-led actions in Ukraine. Since March, responding to the deteriorating situation, US sanctions have continued to escalate. ...more

"Massachusetts Revises Campaign Finance Law"

On August 1, 2014, Massachusetts Gov. Deval Patrick signed House Bill No. 4366 amending the state's campaign finance laws. The amendments, among other things, increase the contribution limit for individual contributors to...more

"State Parties File Legal Challenge Against SEC Rule 206(4)-5"

On August 7, 2014, the New York and Tennessee state Republican parties brought suit against the Securities and Exchange Commission (the SEC), challenging Rule 206(4)-5 (the rule). Specifically, the complaint seeks an...more

Supreme Court Blocks Citizens United Advisory Proposition From Ballot

I’ve previously reported on SB 1272 which was rushed through the legislature and allowed to become “law” without Governor Brown’s signature. The bill, authored by Senator Ted Lieu, calls for an advisory vote on whether the...more

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