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U.S. Agencies Caution Foreign-Based Persons on Extraterritorial Reach of U.S. Sanctions and Export Control Regulations

On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more

Four Federal Agencies Reaffirm Authority to Monitor Automated Systems for Unlawful Discrimination and Other Federal Law Violations

On April 25, 2023 four federal agencies—the Consumer Financial Protection Bureau (CFPB), the Federal Trade Commission (FTC), the United States Department of Justice (DOJ), and the U.S. Equal Employment Opportunity Commission...more

United States V. Danske Bank: New Theory of Liability for Violation of US AML Standards

This Article discusses the recent plea agreement between the United States and Danske Bank. It argues that the Department of Justice has advanced a new and evolving theory of liability for foreign banks that access the U.S....more

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