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PayPal To Pay Dearly for Alleged Violations of OFAC Sanctions

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced a $7,658,300 settlement with PayPal, Inc. (PayPal) to resolve potential civil liability for 486 alleged violations of the Iranian,...more

A Modern Approach to Tackling CFIUS Concerns

Foreign direct investment (FDI) into American businesses is a major component of the U.S. economy. American companies use FDI to fund domestic manufacturing plants, research and development facilities, and support the growth...more

UK Budget 2015 – Key Tax Measures

The Chancellor of the Exchequer’s final Budget of the current Parliament, given on 18 March 2015, was held in the shadow of the UK’s general election on 7 May 2015. With the backdrop of the UK’s GDP growth increasing,...more

Commerzbank: Remediation Under the Government Hammer and Microscope (Part III of III)

The Commerzbank bank case provides a chilling story of a systemic breakdown in compliance, and the far-reaching consequences of such a breakdown. Even in the context of a systemic breakdown, there are valuable lessons to be...more

White House Issues Executive Order Targeting Venezuela

On March 8, President Obama signed an executive order imposing sanctions on Venezuela in response to the country’s ongoing human rights violations and abuses in anti-governmental protests. Specifically, the Order (i)...more

Bridging the Week - March 2015 #3

CFTC Chairman Suggests European-CFTC Agreement on Clearinghouse Equivalency May Come Soon; Skin in the Game Debate Needs More Study - In an address before the 40th annual FIA Boca Raton International Futures Industry...more

Commerzbank’s Compliance Catastrophe — Flouting Sanctions and BSA/AML Laws (Part II of III)

Sometimes a picture is very clear but legal words and concepts are proffered in an attempt to disguise and even deceive. As set forth in the factual statements outlined by the government, and agreed to by Commerzbank, it is...more

Commerzbank’s Settlement — The Government’s Frustration Boils Over (Part I of III)

Global banks are caught in US prosecutor’s cross hairs. Not only do they have to worry about basic AML compliance and enforcement, they now have major risks in sanctions compliance. For some inexplicable reasons, global...more

US Imposes Additional Ukraine/Russia- Related Sanctions By Designating Individuals and Entities Pursuant to Executive Orders 13660...

On March 11, 2015, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued further designations pursuant to Executive Order 13660 (EO 13660) and Executive Order 13685 (EO 13685). EO 13660, which was...more

U.S. Implements Targeted Sanctions on Venezuela

On March 9, 2015, following failed diplomatic efforts to bring Venezuela in line with its human rights commitments under international law, President Obama issued an Executive Order (E.O.) declaring Venezuela a national...more

EU asset freeze developments: Ukraine state fund misappropriation list, Syria, Libya

The EU has recently removed four persons from its asset freeze list featuring persons deemed responsible for misappropriation of Ukrainian state funds, and added 13 parties to the Syria related asset freeze list. In addition,...more

Trade & Manufacturing - March 2015

In This Issue: - Foreign Currency Manipulation Front and Center in U.S. Trade Talks - United States Challenges Chinese Export Subsidies at the WTO - Executive Branch Launches Plan to Combat Wildlife...more

Telecommunications in Cuba and the U.S. Embargo: History, Opportunities, and Challenges

Since President Obama announced the United States’ new policy to normalize relations with Cuba, talk about opportunities for U.S. telecommunications companies has flourished. That reaction only intensified when the Treasury...more

Cuba Today

One week ago, I visited Cuba with a delegation from the American Bar Association’s International Law Section. During our visit, we met with government officials, attorneys, law professors, foreign businessmen, journalists...more

Foreign Currency Manipulation Front and Center in U.S. Trade Talks

As the Obama Administration vigorously pursues its trade agenda, bipartisan groups in the House and Senate have brought the issue of currency manipulation to the forefront of the trade policy debate. On February 10,...more

Financial Institutions and Ethics – Some Just Do Not Get It

I am starting to repeat myself – it is a sign of old age (ask my wife), or maybe I have a point to make. I have written several times about financial institutions and the need to embrace a culture of ethics and compliance....more

Tax Policy Update

NUMBER OF THE WEEK: $160,000. The value of one gift bag at the Oscars on Sunday night. According to the Internal Revenue Service, contents of the gift bags cannot be treated as gifts for federal income tax purposes because...more

Alert: Canada Introduces Additional Sanctions Against Russia

On February 17, 2015, the Government of Canada announced that new entities and individuals in Russia and Ukraine have been designated under Canada’s sanctions laws. These new measures are introduced in coordination with the...more

Canada Imposes Additional Sanctions, Including Against Rosneft

On February 17, 2015, the Government of Canada announced a new round of sanctions against Russian and Ukrainian individuals and entities, including leading Russian oil firm NK Rosneft OAO....more

Cuba Sanctions: 10 Important Changes

Ten key changes to US sanctions and export regulations for Cuba. On January 15, 2015, the Departments of the Treasury and Commerce revised the Cuban Assets Control Regulations (CACR) and the Export Administration...more

EU adds more separatists and five Russian officials to Ukraine related asset freeze list

The EU has extended its sanctions in relation to Ukraine by adding 19 persons and nine entities to the asset freeze list. These newly designated parties are deemed to be actively involved in separatist activities in Eastern...more

Sanctions Enforcement – Facilitation Violations

As sanctions enforcement continues to mature, the permutations of risks become more complex. One area where companies have significant exposure is when they can be accused of “facilitation.” ...more

EU sanctions against Russia: New targets and state of play

On 9 February 2015, the EU Foreign Affairs Council imposed new sanctions - asset freezes and travel bans - against 19 Russian and Ukrainian individuals and 9 entities that have been added to the 'black list' of sanctioned...more

After a busy 2014 for sanctions, what can we expect in 2015?

2014 was a very eventful year for sanctions, with both the European Union (EU) and United States (US) making extensive use of trade sanctions to attain foreign policy goals. Certain sanctions measures against Iran were (and...more

Sanctions Update: Continuing Implementation of US Embargo of Crimea Region

New US rules define scope of prohibitions and authorized activities, as Crimea region remains subject to broad US embargo and EU trade and investment restrictions. On January 29 and 30, 2015, the US Department of...more

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