On the eve of the 2024 Group of Seven (G7) Leaders’ Summit, the United States imposed new sanctions and export control measures against Russia further targeting sanctions evaders and, for the first time, the Russian...more
6/19/2024
/ Asset Seizure ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Services Industry ,
Foreign Financial Institutions (FFI) ,
Information Technology ,
Infrastructure ,
International Securities Market (ISM) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Software ,
UK
Parties affected by a force majeure event should exercise "reasonable endeavours" to overcome such an event, even if the contract does not clearly state so.
However, when exercising reasonable endeavours, parties do not...more
On the second anniversary of the start of the war in Ukraine and in response to the death of activist Aleksey Navalny in a Russian prison, the United States, European Union, and United Kingdom, along with Australia and...more
3/4/2024
/ Asset Freeze ,
Australia ,
Bureau of Industry and Security (BIS) ,
Canada ,
China ,
Economic Sanctions ,
Energy Sector ,
EU ,
Export Controls ,
Financial Services Industry ,
India ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Transportation Industry ,
Turkey ,
UK ,
Ukraine ,
United Arab Emirates (UAE) ,
US State Departments
Throughout December, the United States, European Union, and United Kingdom adopted a series of new sanctions packages against Russia that are expansive and multilayered and pose additional compliance challenges.
The new...more
1/11/2024
/ Compliance ,
Economic Sanctions ,
EU ,
Exports ,
Financial Institutions ,
Financial Services Industry ,
Imports ,
Jurisdiction ,
Office of Foreign Assets Control (OFAC) ,
Oil Prices ,
Russia ,
SDN List ,
Software ,
U.S. Treasury ,
UK
In a recent judgment, the English High Court for the first time ruled on a sanctions de-listing case under Section 38 of the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). Following the UK’s departure from the EU,...more
In 2022, the US, UK and EU all escalated their sanctions enforcement rhetoric. For example, senior US enforcement officials went so far as to describe sanctions as “the new FCPA” (referring to the US. Foreign Corrupt...more
2/17/2023
/ Civil Sanctions ,
Compliance ,
Economic Sanctions ,
Enforcement ,
EU ,
Liability ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Russia ,
UK ,
Ukraine
There is a growing trend of shareholders and other stakeholders using litigation to hold companies and their directors accountable regarding ESG issues.
Shareholder activists and other stakeholders are using the courts in...more
The Final Notice against Guaranty Trust Bank (UK) Limited (“GT Bank”) follows on the heels of similar enforcement actions against financial institutions for AML systems and controls breaches, continuing to make good on the...more
Since February 2022, the United States, United Kingdom, and European Union have imposed unprecedented economic sanctions on Russia and various Russian entities and individuals in response to the war in Ukraine.
Actions have...more
12/19/2022
/ Asset Freeze ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
EU ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Good Faith ,
Imports ,
Maritime Transport ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
Safe Harbors ,
SDN List ,
U.S. Treasury ,
UK ,
Ukraine
Key Takeaways -
The FCA has recently fined JLT Specialty Limited and Ghana International Bank for limitations in their financial crime systems and controls, specifically weaknesses relating to anti-money laundering (AML)...more
7/14/2022
/ AML/CFT ,
Anti-Money Laundering ,
Bribery ,
Corruption ,
Cryptoassets ,
Enforcement Actions ,
Financial Conduct Authority (FCA) ,
Financial Crimes ,
Money Laundering ,
UK ,
White Collar Crimes
The national security and foreign direct investment (“FDI”) review landscape around the world is evolving rapidly. A pre-pandemic trend of active FDI reviews in countries around the world has gained momentum and resulted in...more
At a New York City Bar Association event on April 27, Deputy Attorney General Lisa Monaco described economic sanctions as “the new FCPA.” Her characterization should put corporate compliance departments on notice. ...more
5/6/2022
/ Anti-Corruption ,
Compliance Management Systems ,
Corruption ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
FCPA Guidance ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
Military Conflict ,
Policies and Procedures ,
Russia ,
Ukraine ,
White Collar Crimes
In the early hours of 15 March 2022, following a wait of almost five years, the UK Parliament introduced into law the Economic Crime (Transparency and Enforcement) Act (the "Act"). The Act was fast-tracked at an...more
3/22/2022
/ Anti-Corruption ,
Anti-Money Laundering ,
Corruption ,
Financial Crimes ,
Foreign Investment ,
Money Laundering ,
Pending Legislation ,
Regulatory Reform ,
Regulatory Standards ,
UK ,
Unexplained Wealth Orders (UWOs) ,
White Collar Crimes
Background As noted in our prior update, the United States, European Union and United Kingdom imposed a number of sanctions in connection with Russia’s recognition of the Donetsk and Luhansk regions of Ukraine. ...more
2/28/2022
/ Asset Freeze ,
Biden Administration ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
UK ,
Ukraine ,
Vladimir Putin
Russia's Actions -
On February 21, 2022, Russian President Vladimir Putin signed two executive orders recognizing the DNR/LNR Regions as “sovereign and independent states.”...more
2/23/2022
/ Biden Administration ,
Blocked Person ,
Critical Infrastructure Sectors ,
Economic Sanctions ,
Enforcement Priorities ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine ,
Vladimir Putin
Executive Summary - On March 2, 2021, the Biden Administration, in a coordinated announcement by the U.S. Departments of Treasury, State, and Commerce, tightened export restrictions against Russia and imposed sanctions and...more
3/4/2021
/ Biden Administration ,
Chemical Weapons ,
EU ,
Export Controls ,
Exports ,
Global Human Rights Sanctions Regime ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
UK
Amid the uncertainty brought about by the end of the Brexit transition period and the ongoing COVID-19 pandemic, firms should be aware that the FCA will retain an active approach to financial crime and regulatory enforcement...more
2/16/2021
/ Asset Management ,
BSA/AML ,
Economic Sanctions ,
Enforcement Actions ,
Financial Conduct Authority (FCA) ,
Financial Crimes ,
Financial Markets ,
Market Abuse ,
Senior Managers ,
Short Selling ,
UK
The British Parliament has recently published two important post-legislative assessments of the effectiveness of the UK’s financial crime legislative framework, as well as an insight into future areas of focus....more
3/29/2019
/ Anti-Money Laundering ,
Corporate Misconduct ,
Deferred Prosecution Agreements ,
Failure to Prevent ,
Financial Conduct Authority (FCA) ,
Financial Crimes ,
Legislative Reports ,
Ministry of Justice ,
Office of Financial Sanctions Implementation (OFSI) ,
Person with Significant Control (PSC Register) ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
Suspicious Activity Reports (SARs) ,
UK ,
UK Brexit ,
UK Bribery Act ,
UK Criminal Finances Act 2017 ,
White Collar Crimes