On June 26, Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of an enforcement action against an Italian animation company that violated OFAC’s sanctions on North Korea. The enforcement action...more
On May 22, 2024, the Department of Justice’s National Security Division (“NSD”) announced its first declination of prosecution for a company under the voluntary self-disclosure program established by the National Security...more
The Disruptive Technology Strike Force hosted a summit on Feb. 7-8, 2024, in Phoenix, Arizona, to commemorate its one-year anniversary. The Strike Force is an interagency law enforcement effort aimed at preventing...more
For U.S. businesses, sanctions compliance has never been more challenging or more important. The U.S. has responded to Russia’s invasion of Ukraine with a broad range of sanctions targeting the Russian government, its...more
On July 26, 2023, the U.S. Department of Justice’s National Security Division, U.S. Department of Commerce’s Bureau of Industry and Security, and U.S. Department of the Treasury’s Office of Foreign Assets Control issued a...more
In early 2023, the U.S. Department of Justice and U.S. Department of Commerce launched the Disruptive Technology Strike Force to target illicit actors, strengthen supply chains and protect critical technology assets from...more
It has been a little more than a year since Russia’s invasion of Ukraine, and the war continues to rage. In an effort to deter the Russian government and weaken its military capabilities, the United States has imposed...more
The Financial Crimes Enforcement Network (FinCEN) has recently issued an alert cautioning all financial institutions regarding potential investments in the U.S. commercial real estate (CRE) sector, by or on behalf of...more
For a corporation receiving a grand jury subpoena, the most difficult (and expensive) part of a U.S. Department of Justice (DOJ) inquiry is often sifting through corporate data to find relevant material. That is proving to be...more
As the world watched in horror over the atrocities occurring in the war zones of Ukraine this week, global leaders re-doubled their efforts to bring increasing sanctions pressure to bear on Russian industry, the Russian...more
4/11/2022
/ Economic Sanctions ,
Export Controls ,
Financial Institutions ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine ,
Vladimir Putin
As we approach the thirty day mark since the United States, and other Western countries began imposing a series of rigorous sanctions on the Russian economy and key components thereof, we are starting to see real evidence of...more
Last week, the U.S. Department of Justice (DOJ) announced the launch of an aggressive interagency law enforcement task force, Task Force KleptoCapture. The Task Force represents another U.S. enforcement initiative in response...more
Over the last several days, the United States and allies in North America, Europe, and Asia have announced a sweeping expansion of the sanctions levied against Russia and affiliated entities and individuals in the wake of...more
Building on Monday’s Executive Order imposing sanctions on the so-called Donetsk and Luhansk People’s Republics (DNR and LNR, respectively) in Ukraine, the Biden Administration on Tuesday sanctioned two major Russian...more
In response to the deteriorating political and military situation on the Ukraine border, last night the Biden administration issued an initial set of sanctions targeting activities involving the Donetsk and Luhansk regions of...more
As the crisis on the Ukrainian border persists, companies with exposure to Russian markets and counterparties are being forced to reckon with the possibility that a Russian invasion of Ukraine could result in imposition of...more
Global expansion without adequate controls is asking for trouble. That’s the lesson of a $19 million settlement between WPP, the world’s largest advertising agency, and the U.S. Securities and Exchange Commission (SEC) to...more
“Pleading the Fifth” is one of the most commonly known phrases in our legal system, and the right against self-incrimination is one of the Constitution’s most meaningful protections. That said, in the corporate fraud context,...more
Congress stood-up the National Security Commission on Artificial Intelligence (NSCAI) to make recommendations to the President and Congress “to advance the development of artificial intelligence [AI], machine learning, and...more
On Feb. 24, 2021, President Joe Biden signed an executive order (EO) triggering a comprehensive review of U.S. supply chains, ordering agencies to identify ways to secure the American economy against shortages of critical and...more
On December 10, 2020, FinCEN Director Kenneth Blanco delivered prepared remarks at the ABA’s annual Financial Crimes Enforcement Conference. At the outset, Director Blanco addressed the importance of U.S. national security...more
Government contractors should take note of a March 4, 2020, ruling by the 3rd U.S. Circuit Court of Appeals (Court) that lowers the jurisdictional threshold for establishing a claim under the False Claims Act (FCA)....more
When the Trump Administration designated Venezuelan state-owned oil producer Petreoleos de Venezuela (“PdVSA”) on January 28, 2019, pursuant to preexisting sanctions relating to the political situation created by the Maduro...more
The U.S. Court of Appeals for the Second Circuit narrowed the reach of the Foreign Corrupt Practices Act (“FCPA” or “the Act”) in ruling that the government cannot use aiding and abetting or conspiracy statutes to charge a...more
Financial institutions’ ability to share suspicious activity reports (“SARs”) within the corporate organizational structure serves as an important tool for Bank Secrecy Act compliance and risk avoidance. FinCEN began 2017 by...more