On February 24, 2026, the U.S. Securities and Exchange Commission (“SEC”) announced significant updates to its Enforcement Manual (“Manual”), marking the first comprehensive overhaul of the Division of Enforcement’s...more
3/2/2026
/ Compliance Monitoring ,
Enforcement Actions ,
Enforcement Guidance ,
Enforcement Priorities ,
Investigations ,
New Guidance ,
Regulatory Oversight ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Regulation ,
Settlement Agreements ,
Settlement Negotiations ,
Subpoenas ,
Wells Notice
Through a series of recently issued general licenses, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has relaxed its Venezuela Sanctions Regulations (VSR) to create a critical pathway for...more
2/23/2026
/ Compliance Management Systems ,
Contract Negotiations ,
Contract Terms ,
Due Diligence ,
Economic Sanctions ,
Foreign Investment ,
General Licenses ,
Investment ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Regulatory Requirements ,
Risk Management ,
Sanctions ,
U.S. Treasury ,
Venezuela
On January 9, 2026, the U.S. Supreme Court granted a writ of certiorari in SEC v. Sripetch, 154 F.4th 980 (9th Cir. 2025) to resolve a Circuit split concerning what the U.S. Securities and Exchange Commission (“SEC”) must...more
2/3/2026
/ Appellate Courts ,
Corporate Counsel ,
Disgorgement ,
Enforcement Actions ,
Kokesh v SEC ,
Liu v Securities and Exchange Commission ,
Regulatory Authority ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Securities Fraud ,
Securities Regulation ,
Split of Authority ,
Sripetch v Securities and Exchange Commission ,
Statutory Interpretation
Trump administration authorizes transactions involving Venezuelan oil sector, but subject to detailed conditions to align with U.S. policy objectives. Companies seeking to do business with Venezuela should confirm that their...more
2/2/2026
/ Contract Terms ,
Due Diligence ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
General Licenses ,
Hydrocarbons ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Reporting Requirements ,
Trump Administration ,
U.S. Treasury ,
Venezuela
The recent arrest and arraignment of Venezuelan President Nicolás Maduro has profound legal and economic implications, particularly within the oil and gas sector. The Venezuelan oil sector is now in a state of disrepair due...more
1/7/2026
/ Arbitration ,
Bilateral Investment Treaties ,
Debt Restructuring ,
Dispute Resolution ,
Economic Sanctions ,
Executive Orders ,
Foreign Investment ,
Infrastructure ,
International Arbitration ,
Investment ,
Investment Disputes ,
Investor State Dispute Settlement (ISDS) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Restructuring ,
Trump Administration ,
U.S. Treasury ,
Venezuela
Earlier this month, the U.S. Court of Appeals for the Second Circuit, arguably the most influential court in the country for federal securities law matters, issued an important decision regarding the scope of insider trading...more
9/24/2025
/ Appeals ,
Fiduciary Duty ,
Financial Institutions ,
Insider Trading ,
Investment Funds ,
Material Nonpublic Information ,
Misappropriation ,
Rule 10b-5 ,
Securities Exchange Act of 1934 ,
Securities Fraud ,
Securities Litigation ,
Securities Regulation ,
Shareholders
On May 9, 2025, President Donald J. Trump signed a new Executive Order titled Fighting Overcriminalization in Federal Regulations, marking a significant policy shift in how federal agencies and the Department of Justice (DOJ)...more
Recently, we have seen a heightened focus on immigration enforcement. Guidance and internal orders within the Department of Justice (DOJ) signal that it may increasingly utilize the immigration laws to prosecute (criminally...more
3/20/2025
/ Compliance ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Employer Liability Issues ,
Foreign Workers ,
Form I-9 ,
Immigration Enforcement ,
Immigration Procedures ,
Penalties ,
Popular ,
Visas
On February 10, 2025 President Trump issued an executive order titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” The order directs the DOJ to halt Foreign Corrupt...more
2/13/2025
/ Anti-Corruption ,
Attorney General ,
Bribery ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Regulatory Reform ,
Securities and Exchange Commission (SEC)
On September 9, 2024, three of the SEC’s five Commissioners voted to approve the new PCAOB Quality Control Standard QC 1000 A Firm’s System of Quality Control. The new standard will substantially revise and refine public...more