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SEC Settlement with Layne Christensen Raises New Questions on the Government’s Understanding of the Business Nexus Element of the...

Last week the SEC settled charges against Layne Christensen for various violations of the FCPA. While a relatively unremarkable case at first glance, the SEC’s charges against Layne Christensen reflect a troubling approach by...more

Sanctions Round-Up: Third Quarter 2014

In this issue: - The Revised OFAC 50 Percent Rule - U.S. and E.U. Sectoral Sanctions Targeting Russia - Additional U.S. Sanctions Targeting Iran - Sanctions Targeting Ongoing Conflicts in Syria,...more

Russia Sanctions: Impact on Financial Institutions in the US, EU and Japan

New sanctions targeting Russia have been implemented in the US, EU and Japan. Although the consequences of breaching the sanctions are severe, navigating the rules is not straightforward. Transactions and business lines will...more

8/25/2014  /  EU , Japan , Russia , Sanctions , SDN List , SSI List

Shearman & Sterling's Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA)/FCPA Digest

In this issue: - Recent Trends and Patterns in FCPA Enforcement - Recent Trends and Patterns in FCPA Enforcement Enforcement - Actions and Strategies - Statistics - Types of Settlements...more

Sanctions Round-Up: Second Quarter 2014

In this issue: - US Authorities End Quarter Full of Enforcement Actions with $8.9 Billion BNP Settlement - US and EU Make Numerous Ukraine-Related Designations as Separatist Aggression Continues - US...more

So You Want to See Messi, Neymar, Ronaldo, and Xavi: Brazil Issues Directive Barring Government Officials From Receiving World Cup...

Earlier today, the Office of the Comptroller General in Brazil, Controladoria-Geral da União (“CGU”), issued a sweeping directive barring government officials from accepting offers to attend or participate in the upcoming...more

OFAC Settles Civil Enforcement Action with Dutch Company for Alleged Violations of US Trade Embargo on Cuba

The US Treasury’s Office of Foreign Assets Control (OFAC) and Carlson Wagonlit Travel B.V. (CWT), a Netherlands-based company, have agreed to settle violations of the Cuban Assets Control Regulations (CACRs) dating back to as...more

Sanctions Round-Up: First Quarter 2014

In this edition: - Implementation of the Joint Plan of Action with Iran - Additional US Iran-Related Sanctions and Licenses - OFAC Civil Settlements - US and EU Sanctions in Response to the Situation in...more

A Potential Fork in the Road: US and EU Sanctions Relating to the Ukrainian Crisis

Both the United States and the European Union have issued calibrated Ukraine-related sanctions as a direct response to the recent political upheaval in Ukraine. Although both US and EU sanctions target certain persons for...more

4/2/2014  /  EU , Russia , Sanctions , Ukraine

New York Court Affirms Separate Entity Ruling on Appeal

On March 11, 2014, a New York state appellate court affirmed an important decision on the “separate entity” rule that is favorable to all multinational banks that maintain a New York branch. New York’s separate entity rule...more

Sanctions Round-Up: Fourth Quarter 2013

As 2013 drew to a close, a potentially groundbreaking agreement was reached with Iran regarding its nuclear program, leading to much speculation about how certain sanctions might be suspended, and under what conditions. While...more

January 2014 Recent Trends and Patterns in Foreign Corrupt Practices Act (FCPA) - Enforcement report only

In this issue: - Enforcement Actions and Strategies - Perennial Statutory Issues - Unusual Developments - Compliance Guidance - Private Litigation - Enforcement in the United...more

Opportunities and Pitfalls of Proposed Easing of Iran Sanctions

After years of fitful progress and failure, Iran and the five permanent members of the United Nations Security Council (China, France, Russia, the United Kingdom, and the United States) and Germany (collectively the “P5+1”)...more

Iran Notices Update: SEC-Registered Issuers Continue to Adapt to Their New Normal

It has been over eight months since SEC-registered issuers began making mandatory disclosures of business activities in or with Iran. During that period, issuers have filed over 400 Iran Notices with the SEC, including...more

Sanctions Round-Up: Third Quarter 2013

In this edition: - Iranian Sanctions Eased to Allow Additional Humanitarian Exports and Activities - New Iranian Sanctions Designations Announced - Significant Reduction Waivers Extended - Global...more

Sanctions Round-Up: Second Quarter 2013

In this issue: - The Iran Freedom and Counter-Proliferation Act of 2012 - E.O. 13645, issued June 3, 2013 - Enforcement Against Foreign Sanctions Evaders - Enforcement Against Human Rights...more

Sanctions Round-Up: First Quarter 2013

In this issue: - OFAC Releases New SDN Search Tool - Additional Provisions Targeting Iran Go Into Effect - OFAC Continues to Target Foreign Sanctions Evaders - Section 219 Disclosures Begin - Burma...more

What’s Going On – Over A Month Of Section 219 Disclosures Under The Iran Threat Reduction And Syria Human Rights Act Of 2012

Section 219 (codified as Section 13(r) of the Securities Exchange Act) has been in effect for six weeks. During this time, more than 100 SEC-registered reporting issuers have made required disclosures regarding their Iran or...more

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