Sanctions

News & Analysis as of

JPOA Extended until July 2015: “Temporary” Iran Sanctions Relief Continues until July 2015

Since the end of November 2013, the so-called P5 + 1 (the United States and its partners, China, France, the United Kingdom, Germany and Russia) have been negotiating with Iran regarding its nuclear program. The negotiations...more

FCA Publishes Decision Notices In Respect Of Three Former Members Of Keydata’s Senior Management

In this decision report, we consider the FCA’s decision notices issued to the former chief executive, sales director and compliance officer of Keydata Investment Services Ltd in connection with the sale of structured...more

Canada Expands Sanctions on Russia and the Crimea Region of the Ukraine

On Monday, June 29, 2015, the Canadian government expanded its economic sanctions against Russia and the Crimea region of the Ukraine. Three additional individuals and 14 entities were added to the list under the Special...more

Bienvenidos a Habana

And so it begins. After more than 50 years of icy relations, Jeffrey DeLaurentis (a U.S. diplomat at the U.S. Interests Section in Havana) delivered a note from President Barak Obama to Cuban President Raul Castro restoring...more

SEC Sanctions KKR Over Fee Allocations

The SEC filed its first action involving a private equity fund and broken deal expenses. By the time the Commission discovered the question the firm realized it did not have a disclosure policy, retained a consultant to study...more

SEC Sanctions Goldman Based on Market Access Rule

The SEC filed another action based on its market access rule. This time the Respondent is Goldman, Sachs & Co., a wholly owned subsidiary of The Goldman Sachs Group, Inc. In the Matter of Goldman, Sachs & Co., Adm. Proc. File...more

EU Extends Current Sanctions Against Russia and Crimea

Signaling increased tensions with Russia regarding its alleged intervention in eastern Ukraine, the European Union on June 19 and 22, 2015, took action extending sanctions targeting Russia and Crimea, including measures that...more

Russia and Ukraine Sanctions - One Year On

The spring and summer of 2014 saw the United States and European Union impose a range of sanctions relating to Ukraine and Russia in response to the series of events leading to the fall of the Yanukovyich government in...more

Whistleblowing: An Employer’s Guide To Global Compliance

In This Issue: - Foreword - A Summary Across Five Continents - Law and Sanctions - The Legislative Framework: Whistleblower Protections Across the Globe - Global Differences: The Cultural...more

The War Against Cyber Threats: President Obama Ups the Ante

Focusing on overseas cyber threats, President Obama issued an Executive Order on April 1, 2015, which grants authorization to impose sanctions on individuals and entities engaged "in malicious cyber-enabled activities that...more

EU continues sanctions against Russia and Crimea into 2016

On 19 June 2015, the EU Council decided to extend until 23 June 2016 the EU sanctions against Crimea/Sevastopol imposed in June 2014 in response to the annexation of Crimea and Sevastopol. On 22 June 2015, the EU...more

Extension of sanctions on Yemen, Iraq and the Central African Republic: What your firm needs to know

The UK Government has recently extended United Nations (UN) and European Union (EU) sanctions relating to Yemen, Iraq and the Central African Republic to the British Overseas Territories. - Yemen (Sanctions) (Overseas...more

Still Your Father’s Oldsmobile? Stale Bank Holding Company 10-K Sup & Reg Sections

It has been apparent for years that the common boilerplate Supervision and Regulation discussion in most bank holding company Form 10-K Annual Reports could be trimmed down and updated. Instead of rehashing longstanding...more

"US and European Dynamics and the Future of Sanctions on Russia"

Since the outbreak of the Ukraine crisis, the United States and the European Union have sought to align their sanctions responses against Russia. Indeed, this trans-Atlantic bid to leverage economic costs on Russia in...more

Gallagher Chides Commission for Sanctioning IA CCO’S

In a strongly-worded public statement last week, SEC Commissioner Gallagher chided the Commission for “cutting off the noses of CCO’s to spite its face.” Explaining his dissent in two recent enforcement actions imposing...more

Structured Thoughts: News for the financial services community, Volume 6, Issue 4

In This Issue: - FINRA Requests Comments on Proposed Amendments to Rule 2210 and Issues Additional FAQs - FINRA’s Revised Sanction Guidelines - A Uniform Fiduciary Duty Standard and the Structured Products...more

Competition News June 2015

The French Competition Authority departs substantially from its method for calculating fines in the poultry cartel cases - In its poultry cartel decision of May 6, 2015, the French Competition Authority was forced to...more

FINRA Fines Financial Firm for Failing to Encrypt Customer Data on Lost Laptop

Like other federal agencies exercising regulatory power in the data privacy and security arena, the Financial Industry Regulatory Authority (“FINRA”) is cracking down on firms that fail to meet required data security...more

SEC Announces First Wave of MCDC Underwriter Sanctions

The Securities Exchange Commission announced June 18 the first major wave of underwriter sanctions under its Municipalities Continuing Disclosure Cooperation (“MCDC”) Initiative. The SEC sanctioned 36 municipal underwriting...more

One step closer to European privacy regulation? Five unsettled issues

EU Justice and Home Affairs ministers this week reached a general approach on the General Data Protection Regulation at their Council meeting. This means that, more than three years after the Commission’s initial...more

Financial Industry Compliance: Enforcement Challenges in the US and Europe

“If you look at the landscape pre-financial crisis, i.e. in 2006-2007, compliance looked very different than it does now,” said Latham & Watkins partner Dr. Finn Zeidler. “In the meantime, compliance in the financial services...more

The French Data Protection Authority Puts Google On Notice To Delist Domain Names Beyond Site’s EU Extensions

One, of course, recalls the May 13, 2014 decision of the Court of Justice of the European Union (CJEU) on the “right to be forgotten”. As a result, the French Data Protection Authority (CNIL – Commission Nationale de...more

Substantially Increased Sanctioning Powers of the Dutch Data Protection Authority

A newly passed bill in the Netherlands has increased the fining power of the Dutch Data Protection Authority (DPA) to up to EUR 810,000 or 10 percent of an organization’s annual worldwide turnover. On May 27, 2015, the...more

PTAB to Consider Motion for “Abuse of Process” Sanctions Against Kyle Bass Hedge Fund IPR Petition

In a recent order, the Patent Trial and Appeals Board (PTAB) indicated that it will consider a motion for sanctions based on a claim of “abuse of process” in Inter Partes Review (IPR) proceedings filed by the Coalition for...more

The Foreign Corrupt Practices Act: At a Glance

In this issue: - FCPA AT A GLANCE - THE ANTI-BRIBERY PROVISIONS OF THE FCPA - TO WHOM THE ANTI-BRIBERY PROVISIONS APPLY - THE PAYMENT ELEMENT - THE CORRUPT INTENT ELEMENT - WHO IS A...more

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