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Implications of U.S. Sanctions Program on Intellectual Property Owners

To advance U.S. foreign policy and national security objectives, the U.S. maintains laws and regulations that impose economic sanctions against certain countries, individuals, and entities (the "U.S. Sanctions Program"). 31...more

The Battle Of Shiloh, Corruption In Ukraine And Things To Come

On this day 126 years ago the two-day battle of Shiloh ended. On the second day, the Union troops under General Grant largely recovered the ground that the Confederate troops had taken on the first day. Grant was severely...more

Business News Digest – April 2014

In this issue: - Cybersecurity Assessments – Using the Tool Well - A SOX in the Gut: Supreme Court Vastly Expands Workplace "Whistleblower" Law - SEC to Scrutinize Never-Examined Investment...more

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

Corporate and Financial Weekly Digest - Volume VIII, Issue 47

In this issue: - Concurrent Resolution of FCPA, Export Controls and Sanctions Violations Demonstrates Close Cooperation of Federal Agencies - Five Agencies Issue Final Volcker Implementation Rules; Small Banks...more

SEC Sanctions Three More Investment Advisers for Compliance Violations

The SEC’s Compliance Program Initiative bore more enforcement fruit. SEC today sanctioned three investment advisory firms for repeatedly ignoring compliance problems. The Initiative targets firms that fail to address...more

Questions On World Bank Sanctions Program

When first conceived, the World Bank’s comprehensive sanctions and debarment program was seen as a significant milestone in the fight against fraudulent, corrupt, collusive and coercive practices on the part of contractors...more

Giving the CCO Teeth: SEC Sanctions Portfolio Manager for Misleading CCO

The SEC brought its first action for misleading and obstructing the work of a CCO this week, finding that a portfolio manager deliberately altered documents and misled the firm’s CCO in an attempt to hide violations of the...more

The Heart Of AML Compliance: Sanctions Violations

The increase in AML enforcement has focused on sanctions violations. ...more

SEC Settles with Service Providers and Trustees of two Mutual Fund Trusts for Inaccurate Disclosures Regarding Section 15(c)...

On May 2, 2013, the SEC filed an order instituting settled administrative proceedings against the trustees (“Trustees”) and certain service providers of two “turnkey” open-end series investment companies, Northern Lights Fund...more

SEC Sanctions Fund Trustees for Inadequate Disclosures and Failure to Follow Compliance Policies

The Securities and Exchange Commission today charged the trustees of two “turnkey” mutual fund trusts with causing untrue or misleading disclosures about their review of the funds’ advisory contracts. The Commission also...more

Bank Indonesia revises the single presence policy for banks – Implications for the banking sector

Background - On 26 December 2012 (the “Effective Date”), Bank Indonesia (“BI”) published Regulation No. 14/24/PBI/2012 (“Regulation 14”) which contains a revised version of the single presence policy applicable to...more

Eased Sanctions Present New Opportunities and Risks

In last month’s newsletter, we discussed how developments in 2012 had considerably tightened sanctions against Iran, including through the first-ever application of sanctions to separately incorporated subsidiaries of U.S....more

Final Regulations Governing Closure of Long Term Care Facilities

The federal Centers for Medicare and Medicaid Services (CMS) published a final regulation to further implement section 6113 of the federal health reform law, the Patient Protection and Affordable Care Act. The March 19, 2013,...more

Whistleblowers: A Dilemma For The Defense

Originally published in Law360 on December 18, 2012. Without a doubt, the advent of the U.S. Securities and Exchange Commission’s whistleblower bounty program prompted a drastic increase in the number of individuals...more

Tough New Iran Sanctions Could Impact Automotive Suppliers

Multinational companies in the automotive supply sector could face heightened enforcement risks under new sanctions on Iran. Effective March 8, 2013, U.S. parent companies will become liable for Iran-related sanctions...more

New Reporting Requirements Under the Iran Threat Reduction and Syria Human Rights Act of 2012

On August 10, 2012, the United States delivered its latest economic blow to Iran by enacting the Iran Threat Reduction and Syria Human Rights Act of 2012. U.S. companies have long been forbidden from engaging in most...more

Banks Take It On The Chin

The end of the year was very tough for global banks. For months significant enforcement actions were expected in the ongoing LIBOR manipulation probe and anti-money laundering and sanctions violations probes....more

Stepping Into the Ring Against the SEC and FINRA: Sometimes It Pays to Duke It Out Against the Regulators

Originally published in Thomson Reuters - Securities Regulation Law Journal - Winter 2012. Faced with the possibility of litigating against the Securities and Exchange Commission (SEC) or the Financial Industry...more

When A Whistleblower Investigation Turns Criminal

The new SEC bounty-hunter regime, the explosion in whistleblower claims, and the increasing severity and complexity of those claims raises the specter of government investigations and criminal sanctions....more

The SEC’s Annual Report on the Dodd-Frank Whistleblower Program: Statistics Suggest Best Practices for an Effective Compliance and...

The Securities and Exchange Commission’s Annual Report on the Dodd-Frank Whistleblower Program, released November 2012, provides the first complete year of data on the activities of the Office of the Whistleblower (“OWB”)...more

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