On October 21, 2019, the U.S. District Court for the Southern District of New York entered final judgment in Lacewell v. Office of the Comptroller of the Currency, the closely-watched case between the New York DFS and the...more
On May 2, 2019, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)—the U.S. agency tasked with administering and enforcing the U.S.’s economic and trade sanctions programs—published A Framework for...more
5/23/2019
/ Audits ,
Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Economic Sanctions ,
Enforcement ,
Federal Sentencing Guidelines ,
Foreign Entities ,
Foreign Financial Institutions (FFI) ,
Internal Controls ,
Interpretive Opinions ,
Jurisdiction ,
Law Enforcement ,
Multinationals ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Management ,
Training
On May 2, 2019, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)—the U.S. agency tasked with administering and enforcing the U.S.’s economic and trade sanctions programs—published A Framework for...more
5/17/2019
/ Audits ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Economic Sanctions ,
Enforcement ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Training ,
U.S. Treasury
On Thursday, May 2, 2019, Judge Victor Marrero of the Southern District of New York issued an important decision in the closely watched Vullo v. Office of the Comptroller of the Currency et al., No. 1:18-cv-08377. Judge...more
On April 24, 2018, the Supreme Court of the United States will hear arguments on the issue of whether a court may exercise independent review of the meaning of a foreign country’s domestic law, or whether a court is “bound to...more
Last week, the Second Circuit affirmed that U.S. courts should, and indeed must, defer to a foreign government’s interpretation of its own laws. That should hardly be a controversial proposition, but up until now, lower...more