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Ramifications of US Election for International Sanctions

Yesterday’s election has significant implications for international sanctions, particularly with respect to Iran, Cuba, and Russia. Although we do not want to be unduly alarmist, President-elect Trump’s statements on the...more

NYS Department of Financial Services Outlines Requirements for Transaction Monitoring and Filtering Programs of NY State-Licensed...

On June 30, 2016, the New York State Department of Financial Services (“NYSDFS”) adopted a final regulation outlining the attributes of a risk-based transaction monitoring and filtering program that certain New York...more

Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA) / FCPA Digest - July 2016

Shearman & Sterling’s bi-annual Trends & Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA...more

FinCEN Issues Final Beneficial Owner Identification Rules

In May 2016, the U.S. Treasury Department’s Financial Crimes Enforcement Network issued final rules regarding beneficial owner identification obligations for legal entity customers (the “Rule”). Under the Rule, covered...more

To Self-Report or Not to Self-Report, That Remains the Question After the Justice Department’s Latest Effort to Encourage...

On April 5, 2016, the United States Department of Justice, Criminal Division, Fraud Section launched a one-year Pilot Program that invites companies to self-report potential violations of the Foreign Corrupt Practices Act...more

Sanctions Round Up First Quarter 2016

OFAC amends the Cuban Assets Control Regulations to ease Cuban sanctions in response to President Obama’s policy changes announced on December 17, 2014. These revisions have major implications for the banking and financial...more

Sanctions Round-Up: Fourth Quarter 2015 and “Implementation Day”

The International Atomic Energy Agency certifies that Iran had complied with all nuclear-related requirements of the Joint Comprehensive Plan of Action leading to the end of United States sanctions against the country...more

Navigating Iran Sanctions After Implementation Day

Although the United States, the European Union, and the United Nations lifted a number of sanctions targeting Iran on January 16, 2016 (“Implementation Day”) in accordance with the terms of the recent Iran nuclear deal, the...more

FCPA Digest - January 2016

The FCPA Digest provides and an invaluable compendium of all Foreign Corrupt Practices Act (FCPA) enforcement actions and private actions including US foreign bribery proceedings including criminal prosecutions, DOJ foreign...more

Iran Sanctions Relief: Opportunities and Challenges for US and EU Financial Institutions

Although US and EU sanctions targeting Iran are not likely to be lifted before early 2016, there are a number of issues which US and EU-based financial institutions should be aware of in preparation for sanctions relief as a...more

Court Upholds Partial Invalidation of SEC Conflict Minerals Rule

On August 18, 2015, a divided panel of the US Court of Appeals for the District of Columbia Circuit, in National Association of Manufacturers v. Securities and Exchange Commission (“NAM”), upheld its earlier ruling that held...more

Latin America Corruption: Keep Calm, Carry On?

Recently, governmental authorities have pursued corruption investigations in Latin America with a vigor traditionally not seen. One potential result is a significant disruption of business. While there are inherent risks in...more

Sanctions Round Up: Second Quarter 2015

After almost two years of negotiations, the P5+1 and Iran reach a final comprehensive agreement regarding Iran’s nuclear program, which will likely result in the gradual lifting of international and US sanctions by early next...more

Looking Ahead to Lifting Sanctions Against Iran - Key takeaways from the July 22, 2015 conference call

On July 22, 2015, Shearman & Sterling hosted a client call on Iran sanctions led by Dan Newcomb, Anthony Patten, Barney Reynolds and James Campbell to examine the impact of this historic agreement and discuss how companies...more

Looking Forward to Lifting of Sanctions Against Iran

After almost two years of negotiations, on July 14, 2015, the E3/EU+3 (China, France, Germany, Russia, the United Kingdom and the United States) and Iran reached an agreement regarding Iran’s nuclear program. The Joint...more

Changes to Sanctions on Iran

What are the prospects for business with Iran after the June 30 deadline to complete negotiations over Iran’s nuclear program? In exchange for limitations on Iran’s ability to develop nuclear weapons, the European Union...more

FIFA and BHP Billiton: The Unique FCPA Challenges Present in International Sports

Recent enforcement actions by the Department of Justice and Securities and Exchange Commission have raised the profile of corruption in international sport and highlight unique FCPA compliance concerns. This note will explain...more

Changes in US Sanctions on Cuba Present Opportunities and Challenges

The Obama Administration’s recent loosening of trade restrictions on Cuba has the potential to open new opportunities for US businesses. However, there are several obstacles to be overcome before US companies may access...more

Sanctions Round-Up: First Quarter 2015

In this edition: - US and EU continue targeting Russia for its activity in Ukraine - Cuba-related regulatory reforms announced - P5+1 and Iran reach framework agreement - US enforcement actions:...more

"Facilitation": A New Tool for Extraterritorial Sanctions Enforcement?

Recent OFAC and DOJ actions have focused on certain entities – overseas financial institutions – and particular conduct – US dollar clearing and associated “stripping.” The DOJ’s recent $232 million settlement and negotiated...more

Sanctions Round-Up: Fourth Quarter 2014

In this issue: - US and EU continue sanctions against Russia for its activity in Ukraine; - US and EU sanctions against the Crimea region; - US makes major change in Cuban relations; - The EU...more

FCPA Digest - January 2015

In this issue: - Recent Trends and Patterns in FCPA Enforcement - Foreign Bribery Criminal Prosecution Under the FCPA - Foreign Bribery Civil Actions Instituted by the Department of Justice under the...more

Gifts of Travel and Luxury Watches to Saudi Officials Not Mere 'Icing on the Cake' for FCPA Charges

Improper Gifts Alone, Without Cash Bribes, Serve as Basis for SEC’s Latest FCPA Enforcement Action - Earlier this week, the SEC announced fines for two former defense contractor employees for FCPA violations relating...more

Navigating Russia Sanctions: US, EU, and Japan Update

US, EU and Japanese sanctions targeting Russia are becoming increasingly aligned as a result of each jurisdiction’s continued tailoring of sanctions targeting Russia. In each jurisdiction there are now laws which block funds...more

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