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Red Notice Newsletter - Russian

LATAM Airlines Agrees to Pay $22 Million to Settle FCPA Cases - Last month, LATAM Airlines (“LATAM”), based in Santiago, Chile, agreed to pay $22 million to settle parallel civil and criminal proceedings involving...more

Red Notice Newsletter - August 2016

LATAM Airlines Agrees to Pay $22 Million to Settle FCPA Cases - Last month, LATAM Airlines (“LATAM”), based in Santiago, Chile, agreed to pay $22 million to settle parallel civil and criminal proceedings involving...more

Is Chinese Investment in the U.S. Film and Entertainment Industry the Next Area of CFIUS Scrutiny?

U.S. lawmakers recently submitted a letter to the Government Accountability Office (GAO) raising concerns about increased Chinese investments in the U.S. film and entertainment industry and questioning whether the Committee...more

Export Control Reform Offers Revisions to Key Terms, and DDTC Increases Penalty Authority; More Work Remains (Part 1)

On June 3, 2016, the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) and the Department of Commerce, Bureau of Industry and Security (BIS) issued changes to the International Traffic in Arms Regulations...more

Red Notice Newsletter - May 2016

ANTICORRUPTION DEVELOPMENTS - Former Securency Manager Convicted of Corruption - On May 11, 2016, Peter Michael Chapman, former manager of polymer banknote manufacturer Securency PTY Ltd. (“Securency”), was...more

DOJ Civil Rights Division Underscores Risk of Discrimination Claims When Requesting Information from Applicants and Employees for...

On March 31, 2016, the Department of Justice’s Civil Rights Division (“DOJ”) issued a technical assistance letter (TAL) that highlights the potential for employers to create discrimination claims inadvertently when requesting...more

Red Notice Newsletter - April 2016

ANTICORRUPTION DEVELOPMENTS – Final Judgments Entered Against Seven Former DAP Employees; Four Ordered to Pay - The Securities and Exchange Commission (SEC) announced earlier this month that on April 6 and 7, 2016,...more

The Panama Papers: Managing Corporate Risk and Uncertainty

On April 3, 2016, it became public that an anonymous source had leaked 11 million confidential documents, known as the “Panama Papers,” belonging to the Panama-headquartered international law firm Mossack Fonseca. As more of...more

Red Notice Newsletter - March 2016

ANTICORRUPTION DEVELOPMENTS – Olympus to Pay $646 Million for Anti­Kickback and FCPA Violations - Early this month, Olympus Corp. of the Americas (OCA) settled government investigations related to violations of the...more

OFAC Authorizes Certain Commercial Passenger Aircraft Transactions with Iran

On March 24, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License I authorizing U.S. persons to undertake certain transactions ordinarily incident to the negotiation of, and...more

Obama Administration Further Eases Sanctions in Advance of Cuba Visit

On Wednesday, March 16, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) implemented amendments to the Cuban...more

China Continues to Dominate CFIUS Review (Update)

On February 19, 2016, the Committee on Foreign Investment in the United States (CFIUS) released its annual report to Congress. CFIUS is an interagency committee that reviews the national security risks associated with...more

China Continues to Dominate CFIUS Review

On February 19, 2016, the Committee on Foreign Investment in the United States (CFIUS) released its annual report to Congress. CFIUS is an interagency committee that reviews the national security risks associated with...more

Obama Administration Further Relaxes Sanctions in Support of Cuba Policy

If you read one thing… - Further relaxation of sanctions on Cuba, effective on January 27, 2016, allows U.S. financial institutions to finance authorized exports and reexports to Cuba of items other than...more

What Implementation of the Iran Nuclear Deal Means for Non-U.S. Companies

On January 16, 2016, the International Atomic Energy Agency (IAEA) verified, and U.S. Secretary of State John Kerry confirmed, that Iran had implemented its key nuclear-related measures described in the Joint Comprehensive...more

What Implementation of the Iran Nuclear Deal Means for U.S. Companies and Their Subsidiaries Abroad

If you read one thing... - There are far greater opportunities for U.S. companies with respect to Iran, particularly through foreign subsidiaries and in the commercial aviation sector, however, U.S. persons and...more

Budget Deal Includes Repeal of U.S. Crude Oil Export Ban

On December 15, 2015, U.S. congressional leaders announced a year-end budget compromise that removes the ban on the export of crude oil from the United States. In exchange for this concession, the Democratic-led opposition to...more

OFAC Expands List of Medical Supplies Eligible for Export to Iran under General License

On November 2, 2015, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated the List of Medical Supplies eligible for export or reexport to Iran under the general license set forth at Section...more

U.S. Government Approves Crude Oil Swaps with Mexico While Congress Considers Repealing the Underlying Export Restrictions

On August 14, 2015, the U.S. Department of Commerce’s, Bureau of Industry and Security (BIS) indicated that it would approve a number of export license applications permitting parties in the United States to swap crude oil...more

Sanctions Relief to Expect from the Nuclear Deal with Iran

On July 14, 2015, Iran and the P5+1 countries (China, France, Germany, Russia, the United Kingdom and the United States), with the High Representative of the European Union for Foreign Affairs and Security Policy, finalized...more

OFAC Issues Venezuela Sanctions Regulations

On July 10, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published, in abbreviated form, Venezuela Sanctions Regulations (VSR) in 31 C.F.R. Part 591. The VSR implement the Venezuela...more

Pushing Deadline for Iran Nuclear Deal, Negotiators Extend Temporary Sanctions Relief for Seven Days

As nuclear negotiations in Vienna reach the targeted June 30, 2015, deadline for an agreement, the P5+1, EU and Iran agreed today to extend the limited and temporary sanctions relief to Iran through July 7, 2015. The...more

State and Commerce Seek Comments on Proposed Export Control Rules Regarding Electronic Transmissions, Defense Services and Other...

On June 3, 2015, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) and the Department of Commerce’s Bureau of Industry and Security (BIS) published proposed rules amending the International Traffic...more

DDTC Proposes New Rule to Clarify its Position on Registration and Licensing of U.S. Persons Providing ITAR Defense Services to or...

On May 26, 2015, the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) released a proposed rule to amend the International Traffic in Arms Regulations (ITAR) with respect to the provision of defense...more

6/1/2015

OFAC Issues Guidance Regarding the Parameters of Authorized Travel Between the U.S. and Cuba

On May 5, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance regarding travel between the United States and Cuba. In particular, the guidance clarifies that companies authorized to...more

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