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US Department of Justice Refines Incentives for Corporate Disclosure of Potential FCPA Violations

Speaking at a conference in Maryland on November 29, 2017, Deputy Attorney General Rod Rosenstein announced a revised Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (“CEP”). This policy builds on the...more

US Implements Changes to Cuba Sanctions

The U.S. Government this week announced changes to U.S. sanctions against Cuba to implement various policy changes announced by President Trump in July 2017 (for additional background, see our prior OnPoint from June 2017)....more

Germany: New Notification Obligation Regarding Certain Foreign Investment Transactions in Germany

Highlights: - Acquisitions of 25% or more of a Germany company by a non-EU/EFTA investor are subject to the German foreign trade law. - Certain industry sectors of the German economy have been identified to be of...more

EU Calls for Greater Scrutiny of Foreign Investments in Strategic Sectors

In his State of the European Union speech on September 13, 2017, the President of the European Commission (the “EC”), Jean-Claude Juncker, announced a proposed regulation which would create a new framework for closer...more

US Imposes Sanctions on Venezuelan Government Securities

The United States announced new sanctions against the Venezuelan Government on August 25, 2017 that target the government’s ability to access U.S. debt and equity markets. The measures are intended to pressure Venezuelan...more

BREAKING: President Trump Signs Russia/Iran/North Korea Sanctions Bill

Yesterday, President Trump signed H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act,” enacting into law limited additional sanctions against Russia and, critically, restricting his ability to suspend or...more

House Passes Bill Authorizing Additional Sanctions Against Russia, North Korea and Iran

After weeks of discussion and procedural uncertainty, the U.S. House of Representatives passed new legislation by a vote of 419–3 that, if enacted into law, will strengthen existing sanctions against Russia and also impose...more

Germany: Recent Amendments on Review of Foreign Investments - Steps to Take When Making an Investment in Germany

The German government agreed last week to amend the German Foreign Trade and Payments Ordinance (AWV) to address potential concerns raised by foreign investments in certain sectors of the German economy. The amended AWV...more

President Trump’s Cuba Policy Changes Have Limited Practical Impact – For Now

President Trump announced just before the weekend that he will reinstate certain travel and commercial restrictions related to Cuba that had been eased under the Obama Administration. While President Trump declared that he...more

US Government Modifies Sanctions Against Russia/Crimea

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) imposed sanctions on additional Russian and Crimean persons while also issuing a general license authorizing certain transactions with a...more

Following CFIUS Recommendation, President Obama Blocks Chinese Acquisition of US-German Semiconductor Equipment Manufacturer

President Obama issued an executive order on December 2, 2016 blocking the sale of the U.S. business of Aixtron SE (“Aixtron”), a German semiconductor manufacturer, to a German subsidiary of a Chinese fund, Fujian Grand Chip...more

Anti-bribery compliance in India: Both sword and shield

In recent years, both the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have stepped up their enforcement of the Foreign Corrupt Practices Act (FCPA), including to address...more

Recent Developments on Review of Foreign Investment into Germany: Is the German Government Tightening the Rules?

A brief orientation on the German foreign investment approval procedure - Highlights - - For the first time ever the German Federal Ministry for Economic Affairs and Energy has withdrawn an already granted...more

U.S.-Russia Business Climate Likely to Change Under Trump Presidency

Donald Trump’s election has the potential to significantly reshape U.S.-Russia relations, but whether any change occurs will depend largely on his willingness to offer Russia a clean slate and whether the U.S. Congress...more

FCPA Enforcement Action Highlights Risks for the Financial Services Industry and Individual Executives

New York-based hedge fund Och-Ziff Capital Management Group (the “Hedge Fund”) agreed to pay approximately $412 million to resolve charges brought by the U.S. Securities and Exchange Commission (“SEC”) and Department of...more

Financial Services Quarterly Report - Third Quarter 2016: Managing the Compliance Aspects of Private Equity Investments

International business transactions can be subject to intense scrutiny due to the broad scope of the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, in addition to other similar anti-corruption measures...more

District Court Upholds Indictment of Turkish/Iranian Billionaire Charged with Evading US Economic Sanctions against Iran

U.S. District Court Judge Richard M. Berman denied a motion to dismiss the indictment in the closely followed criminal prosecution of Reza Zarrab, a Turkish/Iranian businessman charged with conspiring to evade U.S. economic...more

U.S. Government Issues Guidance to Reassure U.S. Banks Involved in Foreign Correspondent Relationships

The U.S. Department of the Treasury, together with other U.S. government agencies responsible for enforcing anti-money laundering (AML) and economic sanctions regulations, released guidance on August 30, 2016 in the form of a...more

United States Further Eases Economic Sanctions on Burma/Myanmar

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) eased certain sanctions against Burma/Myanmar on May 17, 2016, including by allowing most transactions involving Burmese financial institutions....more

Foreign Financial Institutions Beware: United States Expands Economic Sanctions Against Hizballah

Effective April 16, 2016, the United States will implement sanctions pursuant to the Hizballah International Financing Prevention Act of 2015. The new sanctions target Hizballah (or Hezbollah) and non-U.S. persons who support...more

UK Financial Sanctions Enforcement – New Powers and Tougher Sentences

The UK Government put a package of proposals to Parliament in February to increase both the type and the potential severity of consequences for persons and companies who breach EU financial sanctions. If approved, these...more

US Commerce and Treasury Departments Further Ease Restrictions Against Cuba

The U.S. Commerce and Treasury Departments announced on January 26, 2016, actions to ease certain restrictions on transactions involving Cuba. The new actions do not significantly expand the types of activities in which U.S....more

Iran Sanctions: What is Prohibited or Licensable for EU Businesses?

Despite the easing of sanctions on Iran on 16 January under the Joint Comprehensive Programme of Action (JCPOA), some prohibitions and licensing requirements continue to apply to EU businesses. These are summarised below,...more

Implementation Day: Iran Sanctions Eased Today

On Saturday, 16 January 2016, the International Atomic Energy Association (IAEA) submitted a report to the United Nations Security Council (UNSC) certifying that Iran has satisfied its obligations under the Joint...more

Iran Sanctions: Early Easing of Sanctions Increasingly Possible

Public officials from the United States increasingly are making public statements regarding the likelihood that “Implementation Day” – the day on which many US and EU sanctions against Iran will be eased – will arrive in the...more

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