U.S. sanctions enforcement is evolving to adopt a “control” analysis similar to the analysis employed by the European Union and United Kingdom based on a recent major enforcement action by the U.S. Department of the...more
On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the “Blanche Memorandum”) detailing new guidelines for the Department of Justice’s approach to investigating and enforcing the Foreign Corrupt...more
The Anti-Terrorism Act (ATA) created a federal cause of action enabling U.S. nationals injured by reason of an "act of international terrorism" to sue those allegedly responsible for their injuries; it was later amended to...more
On October 4, 2023, the Department of Justice’s (“DOJ”) Deputy Attorney General Lisa Monaco announced a new “Mergers & Acquisitions Safe Harbor Policy” (“M&A Safe Harbor Policy” or “Policy”) for companies that voluntarily...more
10/19/2023
/ Acquisitions ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Disclosure ,
Disgorgement ,
Individual Accountability ,
Mergers ,
Remediation ,
Restitution ,
Safe Harbors ,
Self-Disclosure Requirements ,
Sensitive Business Information
In December 2022, Congress handed would-be whistleblowers reporting money laundering and sanctions violations fresh financial incentives when it passed the Anti-Money Laundering (AML) Whistleblower Improvement Act. The Act...more
On October 3, the International Consortium of Investigative Journalists began reporting on millions of confidential documents relating to the financial activities of heads of state, international business leaders, and other...more
As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more
12/23/2020
/ Anti-Money Laundering ,
Civil Monetary Penalty ,
Currency Transaction Reports (CTR) ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
FinCEN ,
Internal Revenue Code (IRC) ,
Limited Liability Company (LLC) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities Exchange Act ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury ,
Whistleblowers
On December 13, 2019, the Department of Justice (“DOJ”) released an updated Export Control and Sanctions Enforcement Policy for Business Organizations (“Policy”), revising the prior policy governing voluntary self-disclosures...more
1/17/2020
/ Department of Justice (DOJ) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Exports ,
FCPA Corporate Enforcement Policy (CEP) ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Investigations ,
International Emergency Economic Powers Act (IEEPA) ,
International Sales ,
Non-Prosecution Agreements ,
Regulatory Requirements ,
Sanction Violations ,
Self-Disclosure Requirements
SEC Chairman Jay Clayton has issued a broad warning to companies and individuals trying to “cash in” on the market frenzy surrounding Bitcoin and other cryptocurrencies. His prepared remarks at the Securities Regulation...more
For the first time, the Securities and Exchange Commission has brought an FCPA enforcement action premised entirely on a one-time charitable contribution.
On September 20, 2016, the SEC announced a settled FCPA...more
10/4/2016
/ Bribery ,
Charitable Donations ,
Charitable Organizations ,
China ,
Corruption ,
Due Diligence ,
Enforcement Actions ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
Nu Skin ,
Personal Care Products ,
Popular ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
Subsidiaries ,
White Collar Crimes