On May 12, the Criminal Division of the U.S. Department of Justice (DOJ) issued a series of changes in its white collar enforcement priorities. These changes were announced in the Criminal Division Enforcement Plan, the...more
Effective as of April 8, 2025, the National Security Division of the U.S. Department of Justice (DOJ) has implemented a Data Security Program (the DSP) to address national security risks associated with the transfer of...more
5/6/2025
/ China ,
Compliance ,
Data Security ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Enforcement Actions ,
Export Controls ,
Foreign Entities ,
International Data Transfers ,
National Security ,
Regulatory Requirements ,
Russia
Last week President Trump signed an Executive Order pausing enforcement of the nation’s most robust anti-bribery statute, the Foreign Corrupt Practices Act (“FCPA”). The EO seeks a complete overhaul of the FCPA enforcement...more
2/14/2025
/ Anti-Bribery ,
Attorney General ,
Cartels ,
Compliance ,
Corporate Governance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Securities and Exchange Commission (SEC) ,
Significant Transnational Criminal Organization ,
UK
As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...more
On January 10 and January 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sweeping sanctions targeting Russia’s oil production and exports, military-industrial base, and other...more
On August 9, 2023, former-President Biden issued Executive Order 14105, Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern, which in summary directed the U.S....more
1/24/2025
/ Artificial Intelligence ,
Biden Administration ,
CFIUS ,
China ,
Executive Orders ,
Foreign Direct Investment ,
National Security ,
Reporting Requirements ,
Semiconductors ,
Trump Administration ,
U.S. Treasury
The supplemental appropriations legislation signed into law on April 24, 2024 enacted numerous high-profile provisions addressing aspects of U.S. foreign policy and national security, including provisions that broaden and...more
7/26/2024
/ Compliance ,
Economic Sanctions ,
Financial Services Industry ,
Foreign Policy ,
Interim Final Rules (IFR) ,
International Emergency Economic Powers Act (IEEPA) ,
Liquidation ,
National Security ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Reporting Requirements ,
Russia ,
TWEA ,
Ukraine
The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more
1/26/2024
/ AML/CFT ,
Audits ,
Civil Monetary Penalty ,
Compliance ,
Criminal Penalties ,
Crude Oil ,
Cryptocurrency ,
Due Diligence ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
International Emergency Economic Powers Act (IEEPA) ,
Liability ,
Maritime Transport ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Risk Assessment ,
Sanction Violations
On August 9, 2023, President Biden issued Executive Order 14105 “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern.” The Executive Order targets certain U.S....more
8/18/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Artificial Intelligence ,
China ,
ETFs ,
Executive Orders ,
Foreign Investment ,
Hong Kong ,
Investment ,
Joe Biden ,
Macau ,
National Security ,
Notification Requirements ,
Outbound Transactions ,
Penalties ,
Rulemaking Process ,
Semiconductors ,
Technology Sector ,
U.S. Treasury
The ascending importance of rigorous and compliance with U.S. national security laws, including sanctions and export controls, was underscored on July 26, 2023 with the release of a Department of Commerce, Department of the...more
8/2/2023
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Export Controls ,
FinCEN ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements