• On April 8, 2019, the U.S. government announced its intention to designate the Islamic Revolutionary Guards Corps (IRGC) as a Foreign Terrorist Organization, effective April 15, 2019. This unprecedented action will result...more
4/15/2019
/ Antiterrorism and Effective Death Penalty Act (AEDPA) ,
CAATSA ,
Foreign Policy ,
Iran ,
Iran Sanctions ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Terrorist Threats ,
Trump Administration ,
U.S. Treasury
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
11/27/2018
/ Aircraft ,
Blocking Statutes ,
Cross-Border Transactions ,
Economic Sanctions ,
EU ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Humanitarian Assistance ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
SDN List ,
Special Purpose Vehicles ,
SWIFT ,
Trade Policy ,
Trump Administration ,
Vessels
• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more
8/17/2018
/ Blocking Statutes ,
Economic Sanctions ,
EU ,
Executive Orders ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Winding Down ,
Withdrawal
• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more
5/10/2018
/ Controlled Foreign Corporations ,
Economic Sanctions ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trade Policy ,
Trump Administration
On January 12, 2018, the U.S. administration took three actions relating to Iran -
• First, President Trump waived again the application of certain nuclear sanctions while making clear that the United States will refuse to...more
• Effective October 13, 2017, President Trump declined to provide certification that the JCPOA is in the United States’ national interest. Following this “decertification,” the U.S. Congress has 60 days in which to introduce...more
11/2/2017
/ Anti-Terrorism Financing ,
Decertify ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Nuclear Agreement Review Act of 2015 (INARA) ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Legislative Amendments ,
Members of Congress ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Proposed Legislation ,
SDN List ,
Sunset Provisions ,
Trump Administration ,
U.S. Treasury
ANTICORRUPTION DEVELOPMENTS -
MTS Receives DOJ and SEC Declination Letters Concluding FCPA Investigations -
On August 7, 2017, MTS Systems (MTS), a Minnesota based maker of test systems and industrial position...more
9/2/2017
/ Africa ,
Anti-Corruption ,
Appeals ,
China ,
Civil Liability ,
Compelled Testimony ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
Executive Orders ,
Exports ,
Financial Conduct Authority (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Freight Forwarding ,
Guilty Pleas ,
Hong Kong ,
IPSA ,
Iran Sanctions ,
Libor ,
New Legislation ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Payment Processors ,
Russia ,
Sanction Violations ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Singapore ,
South Africa ,
Trump Administration ,
Venezuela ,
Whistleblowers
• This enforcement action highlights the heightened sanctions compliance and enforcement risk that companies face when engaging third-party consultants to perform due diligence on counterparties. U.S. persons must make clear...more
8/28/2017
/ Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
General Licenses ,
Imports ,
IPSA ,
Iran ,
Iran Sanctions ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Settlement
ANTICORRUPTION DEVELOPMENTS -
U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations -
On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation into...more
8/10/2017
/ Anti-Corruption ,
Bribery ,
Corruption ,
Criminal Prosecution ,
Cuba ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
Fédération Internationale de Football Association (FIFA) ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
Guilty Pleas ,
Hackers ,
Hobby Lobby ,
Iran Sanctions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Sudan ,
Suspensions & Debarments ,
World Bank
ANTICORRUPTION DEVELOPMENTS -
U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations -
On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation into...more
8/10/2017
/ Anti-Corruption ,
Bribery ,
Corruption ,
Criminal Prosecution ,
Cuba ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
Fédération Internationale de Football Association (FIFA) ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
Guilty Pleas ,
Hackers ,
Hobby Lobby ,
Iran Sanctions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Sudan ,
Suspensions & Debarments ,
World Bank
On August 2, 2017, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act of 2017 (Pub. Law. No. 115-44, H.R. 3364) (the “Act”), which significantly expands economic sanctions against...more
8/9/2017
/ Anti-Corruption ,
Anti-Terrorism Financing ,
Arms Embargo ,
Congressional Override ,
Cyber Sanctions ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Oil & Gas ,
Pipelines ,
Privatization ,
Russia ,
SDN List ,
SSI List ,
State-Owned Enterprises ,
Syria ,
Trade Restrictions ,
Trump Administration
ANTICORRUPTION DEVELOPMENTS -
U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations -
On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation into...more
8/3/2017
/ Anti-Corruption ,
Bribery ,
Corruption ,
Criminal Prosecution ,
Cuba ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
Fédération Internationale de Football Association (FIFA) ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
Guilty Pleas ,
Hackers ,
Hobby Lobby ,
Iran Sanctions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Sudan ,
Suspensions & Debarments ,
World Bank
ANTICORRUPTION DEVELOPMENTS -
Linde Group Receives DOJ Declination Pursuant to FCPA Pilot Program -
On June 16, 2017, German based chemical and gas company Linde Group’s American affiliates, Linde North America Inc....more
7/4/2017
/ AIG ,
Anti-Corruption ,
Bribery ,
Civil Monetary Penalty ,
Compliance ,
Corruption ,
Criminal Penalties ,
Cuba ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Disgorgement ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Fédération Internationale de Football Association (FIFA) ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Guilty Pleas ,
Iran Sanctions ,
Kokesh v SEC ,
Office of Foreign Assets Control (OFAC) ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Statute of Limitations ,
Theft ,
Trade Secrets ,
Trump Administration ,
White Collar Crimes
Anticorruption Developments -
SEC Chairman Nominee Jay Clayton Receives Confirmation Hearing -
On March 23, 2017, SEC Chairman Nominee Jay Clayton testified before the Senate Banking Committee at his confirmation...more
4/4/2017
/ Anti-Retaliation Provisions ,
Arrest ,
Bribery ,
CFIUS ,
China ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Federal Pilot Programs ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Investors ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Petrobras ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Senate Confirmation Hearings ,
Sentencing ,
Split of Authority ,
Telecommunications ,
Trump Administration ,
Ukraine ,
Whistleblowers
Acting SEC Chief Limits Subpoena Authority to Enforcement Division Acting Director -
On February 15, 2017,The Wall Street Journal reported that the acting Chair of the Securities and Exchange Commission (SEC), Michael...more
3/2/2017
/ Anti-Corruption ,
Civil Monetary Penalty ,
Compliance ,
Conflict Mineral Rules ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Foreign Corrupt Practices Act (FCPA) ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Rescission ,
Resource Extraction ,
Russia ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
Whistleblowers
ANTICORRUPTION DEVELOPMENTS -
Las Vegas Sands Corporation Agrees to Pay Approximately $7 Million to Resolve DOJ FCPA Enforcement Action –
On January 19, 2017, Las Vegas Sands Corporation (“Sands”), a Nevada-based...more
ANTICORRUPTION DEVELOPMENTS -
Las Vegas Sands Corporation Agrees to Pay Approximately $7 Million to Resolve DOJ FCPA Enforcement Action –
On January 19, 2017, Las Vegas Sands Corporation (“Sands”), a Nevada-based...more
2/1/2017
/ CFIUS ,
Cuba ,
Disgorgement ,
Economic Sanctions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
General Licenses ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Rolls-Royce ,
SCOTUS ,
Suspensions & Debarments ,
World Bank
ANTICORRUPTION DEVELOPMENTS –
DOJ Issues First-Ever Declinations Requiring Disgorgement of Profits to Resolve FCPA Violations -
On September 29, 2016, the Department of Justice (DOJ) for the first time announced...more
11/2/2016
/ Burma ,
Consent Agreements ,
Conspiracies ,
Cuba ,
Declination ,
Disgorgement ,
Exports ,
Foreign Corrupt Practices Act (FCPA) ,
GlaxoSmithKline ,
Iran Sanctions ,
Myanmar ,
Suspensions & Debarments
Former CEO of Harris Corporation’s Chinese Subsidiary Pays $46,000 to Settle Alleged FCPA Violations; No Charges for Company -
On September 13, 2016, the Securities and Exchange Commission (SEC) issued a...more
10/5/2016
/ Airbus ,
Aviation Industry ,
Boeing ,
China ,
Export Controls ,
Film Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
General Licenses ,
Iran Sanctions ,
Russia ,
South Korea ,
Subsidiaries
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
10/4/2016
/ Airbus ,
Aviation Industry ,
Beneficial Owner ,
Boeing ,
Cuban Assets Control Regulations (CACR) ,
Customer Due Diligence (CDD) ,
Deferred Prosecution Agreements ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Narcotics Kingpin Sanctions ,
General Licenses ,
Health Insurance ,
Humana ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List
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
10/4/2016
/ Airbus ,
Aviation Industry ,
Boeing ,
Cuba ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Narcotics Kingpin Sanctions ,
General Licenses ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List
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
10/4/2016
/ Airbus ,
Aviation Industry ,
Beneficial Owner ,
Boeing ,
Cuban Assets Control Regulations (CACR) ,
Customer Due Diligence (CDD) ,
Deferred Prosecution Agreements ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Narcotics Kingpin Sanctions ,
General Licenses ,
Health Insurance ,
Humana ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List