Following Russia’s aggression against Ukraine and consequent far-reaching bans on Russian oil and gas, there is increased reliance by the European Union (“EU”) and United Kingdom (“UK”) on imports of energy products from...more
On 19 December 2025, the Financial Conduct Authority (FCA) imposed a fine of £309,843 on Mr. Russel Gerrity, an experienced petrophysical consultant, for engaging in insider dealing....more
Last week Bracewell discussed the Trump administration’s initial easing of restrictions on Venezuelan oil with General License (GL) 46, which opened the door for US companies to revive the long-inaccessible industry. However,...more
Hours after the US military strike that ousted Venezuelan President Nicolas Maduro, President Trump announced that, “very large US oil companies, the biggest anywhere in the world” would “go in, spend billions of dollars, fix...more
2/4/2026
/ Economic Sanctions ,
Energy Sector ,
Export Controls ,
General Licenses ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Trump Administration ,
U.S. Treasury ,
US Trade Policies
Last month Bracewell highlighted the latest sets of Russia-related sanctions imposed by the United Kingdom, European Union and United States, explaining the potential far-reaching implications of what are the strongest...more
11/25/2025
/ Compliance ,
Compliance Management Systems ,
Due Diligence ,
Economic Sanctions ,
Energy Sector ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Risk Management ,
Russia
In August, Bracewell discussed the evolving impact of UK and EU sanctions on corporations in the energy and infrastructure sectors. In a significant escalation, in October, the UK, US and EU changed the landscape again by...more
In March 2025, British, French and Swiss authorities announced a new international alliance – the International Anti-Corruption Prosecutorial Taskforce (“Taskforce”) — to tackle bribery and corruption...more
Recent months have seen a number of significant sanctions developments, giving rise to changes in the international compliance landscape. In this article, we collect the key issues and set out our analysis of what this means...more
The Deputy Attorney General of the U.S. Department of Justice Office recently issued new guidelines for investigations and enforcement actions of the Foreign Corrupt Practices Act. (FCPA). These new guidelines come as a first...more
Approximately two weeks ago, British, French and Swiss law enforcement authorities announced the creation of a new international alliance. With their joint Founding Statement (“Statement”), the three countries established the...more
President Trump has used tariffs as a significant point of geopolitical leverage since the beginning of his second term. Indeed, his administration dubbed April 2, 2025 “Liberation Day” in honor of a sweeping set of tariffs...more
4/9/2025
/ China ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Human Rights ,
Imports ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Tariffs ,
Trump Administration ,
U.S. Treasury ,
Venezuela
On January 10, 2025, in a final action to, among other things, deter Russian aggression on the international stage, the US Department of the Treasury enacted sweeping new sanctions on the Russian energy sector. Specifically,...more
1/17/2025
/ Biden Administration ,
Blocking Sanctions ,
Economic Sanctions ,
Energy Sector ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
Popular ,
Renewable Energy ,
Russia ,
Sanctions ,
SDN List ,
U.S. Treasury
In recent months, the United Kingdom’s sanctions regime has received noteworthy updates with implications for a range of entities operating both domestically and abroad. The changes are housed in an update to the Russia...more
On September 23, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri announced that the US Department of Justice (DOJ) had issued updated guidance to federal prosecutors in its “Evaluation of Corporate...more
10/4/2024
/ Artificial Intelligence ,
Clawbacks ,
Compensation ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Due Diligence ,
Emerging Technologies ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Good Faith ,
Incentives ,
Mergers ,
Risk Assessment ,
Risk Management ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblower Hotlines ,
Whistleblowers
On 27 August 2024, a Swiss commodity trader entered into a settlement agreement for $48 million with the US Commodity Futures Trading Commission (“CFTC”) in relation to alleged market manipulation charges. This case, rooted...more
On May 10, 2024, Romy Andrianarisoa, former Chief of Staff to the President of Madagascar, was convicted for soliciting bribes from Gemfields Group Ltd (Gemfields), a UK-based mining company specializing in rubies and...more
7/5/2024
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Corporate Misconduct ,
Corruption ,
Enforcement Actions ,
Investigations ,
National Crime Agency (NCA) ,
Reporting Requirements ,
Shareholders ,
UK ,
White Collar Crimes
Greenwashing, or the use of green ‘claims’ to improve a business’ or product’s environmental credentials with consumers, has come under significant scrutiny in recent years. Both the Advertising Standards Authority and the...more
Last week, the Office of Foreign Assets Control (OFAC) announced an interim final rule which amends the recordkeeping and reporting requirements relating to the various economic sanctions programs it enforces. Notably, the...more
As we wrote earlier this month, the Department of Justice (DOJ) made significant news at the recent American Bar Association White Collar Conference. But the Department didn’t stop at announcing its pilot whistleblower...more
3/28/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
American Bar Association (ABA) ,
Data Protection ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Penalties ,
Recidivism ,
Whistleblowers ,
White Collar Crimes
In recent years, the Department of Justice (DOJ) has rolled out a significant and increasing number of carrots and sticks aimed at deterring and punishing white collar crime. Speaking at the American Bar Association White...more
3/13/2024
/ CFTC ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Employee Misconduct ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
IRS ,
Qui Tam ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
On 21 December 2023, Mr Justice Waksman handed down his judgment in the second trial of the Eurasian Natural Resources Corporation (ENRC) saga. The judgment, along with its earlier companions, is extraordinary in many ways...more
2/19/2024
/ Bribery ,
Criminal Conspiracy ,
Criminal Investigations ,
Democratic Republic of Congo ,
Disclosure Requirements ,
Final Judgment ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
Jurisdiction ,
Kazakhstan ,
Serious Fraud Office (SFO) ,
UK ,
Willful Misconduct ,
Zambia