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Supreme Court Clarifies FSIA’s Expropriation Exception in Republic of Hungary v. Simon

Key Takeaways: The U.S. Supreme Court unanimously held that a party cannot establish the U.S. commercial nexus required to invoke the FSIA’s expropriation exception by alleging a foreign state expropriated property in...more

DOJ’s New Guidelines on Repeat Corporate Misconduct: Do They Have Real Teeth?

On October 28, 2021, Deputy Attorney General Lisa Monaco released a memo setting out “Initial Revisions to Corporate Criminal Enforcement Policies.” The memo indicated that the Department of Justice would place greater...more

Russia Sanctions and Export Controls Update - September 2022

I. Additional Export Controls on Russia and Belarus - (a) Export restrictions on a wide range of EAR99 items - Effective September 15, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS)...more

First Circuit Narrows Whistleblower Protections of Sarbanes-Oxley

On July 13, 2022, the United States Court of Appeals for the First Circuit ruled that the whistleblower protections contained in Section 806 of the Sarbanes-Oxley Act (SOX) do not apply to employees who report potential...more

Russia Sanctions and Export Controls Update – July 6, 2022

I. OFAC Prohibits Gold Importation from the Russian Federation - Implementing the declaration of G-7 leaders on June 26, 2022, the United States has joined the UK, Canada and Japan in prohibiting the importation of newly...more

Russia and Belarus Sanctions Update – March 11, 2022

I. Biden Administration Import and Investment Ban Related to Russian Energy - On March 8, 2022, the Biden administration announced its widely anticipated ban on the import of Russian oil and other energy-related...more

Russia Sanctions Update – February 28, 2022: U.S. Imposes Sanctions on Central Bank of Russia, Ministry of Finance, and Sovereign...

On February 28, 2022, the U.S. government announced new sanctions on the Central Bank of Russia, National Wealth Fund, Ministry of Finance, and Russian Direct Investment Fund, dramatically increasing the economic impact of...more

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