The world’s response to Russia’s invasion of Ukraine dominated the first quarter of 2022, as the US and its international partners coordinated efforts to impose unprecedented sanctions designed to isolate the Russian...more
5/4/2022
/ Biden Administration ,
China ,
Cuba ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Foreign Policy ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Ukraine
Since late February 2022, the United States (U.S.), the European Union (EU) and its member states, the United Kingdom (U.K.), and many others — including Japan, Australia, New Zealand, Taiwan and Canada — have imposed...more
4/28/2022
/ Australia ,
Canada ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Foreign Relations ,
Japan ,
Military Conflict ,
New Zealand ,
Popular ,
Russia ,
Sanctions ,
Taiwan ,
UK ,
Ukraine ,
Vladimir Putin
Since late February 2022, the United States (U.S.), the European Union (EU) and its member states, the United Kingdom (U.K.), and many others—including Japan, Australia, New Zealand, Taiwan and Canada—have imposed sweeping...more
3/23/2022
/ Biden Administration ,
Canada ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
UK ,
Ukraine
Over the past week, the United States, the European Union and its member states, the United Kingdom, and several other countries have imposed rounds of sweeping new sanctions on Russia in response to its invasion of Ukraine....more
3/1/2022
/ Biden Administration ,
Canada ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
UK ,
Ukraine
Closing the year with a renewed focus on the People’s Republic of China, the Biden Administration imposed new export restrictions on US-origin technology to Chinese tech firms to hinder the PRC’s military and security...more
1/24/2022
/ Biden Administration ,
China ,
Cyber Attacks ,
Export Controls ,
Exports ,
Forced Labor ,
Hong Kong ,
Imports ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Russia ,
Sanctions ,
Ukraine ,
Virtual Currency
On October 28, 2021, at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa O. Monaco announced revisions to the Department of Justice’s policies, all designed to strengthen...more
The Biden Administration this quarter announced fewer targeted sanctions, but issued several “whole of government” advisories regarding sanctions risks associated with China-related business dealings, as well as virtual...more
10/29/2021
/ Banking Sector ,
Banks ,
Cryptocurrency ,
Customs ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Financial Institutions ,
Office of Foreign Assets Control (OFAC) ,
Sanctions
The release of the Pandora Papers, a leak of approximately 12 million documents, exposed how foreign leaders and private actors use tax havens to conceal their wealth, with the United States a destination of choice. For...more
10/18/2021
/ Anti-Money Laundering ,
Beneficial Owner ,
Due Diligence ,
Financial Fraud ,
Money Laundering ,
Offshore Funds ,
Pandora Papers ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Reform ,
Regulatory Standards ,
Shell Corporations ,
Tax Evasion ,
Tax Haven ,
Trusts ,
White Collar Crimes
This quarter, the U.S. announced new sanctions and trade restrictions on China in response to its perceived intrusions on Hong Kong’s autonomy and reported human rights abuses in Xinjiang. The Trump Administration acted...more
Prosecutors and regulators are signaling an intent to expand accountability amongst cryptocurrency platforms under U.S. laws and regulations, including the Bank Secrecy Act (BSA). On October 8, 2020, the United States...more
This quarter, the U.S. announced new sanctions and trade restrictions on China in response to its recent encroachments on Hong Kong and its reported mistreatment of ethnic minorities. OFAC continued to target shipping...more
COVID-19 has acted as an accelerator, bringing into play scenarios which were previously only contingencies and making contingencies of (and requiring planning for) situations which were previously barely imaginable. The debt...more
In the first half of 2020, the overall number of corporate enforcement actions dropped somewhat from recent years, with only six actions brought by the DOJ and SEC. The number of individual enforcement actions dropped as...more
7/6/2020
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
EU ,
Foreign Corrupt Practices Act (FCPA) ,
Serious Fraud Office (SFO) ,
UK ,
White Collar Crimes
U.S. sanctions authorities remained active in the first quarter of 2020, even as international focus turned toward combatting the COVID-19 pandemic. OFAC and the U.S. State Department imposed secondary sanctions on firms in...more
This is the first edition of U.K. Business Crime Review— an annual publication focused on the outcomes, trends and developments over the past 12 months that are likely to be of interest to businesses operating in the United...more
A Landmark Decision in the Ruta del Sol Arbitration Against ANI Provides Valuable Lessons for Developers and Financiers of Projects in Latin America -
The landmark decision in the Ruta del Sol arbitration against the...more
2/13/2020
/ Bribery ,
Concession Agreements ,
Constitutional Courts ,
Corruption ,
Dispute Resolution ,
Foreign Investment ,
Government Officials ,
International Arbitration ,
Latin America ,
Public Private Partnerships (P3s) ,
Termination Payments
On 31 January 2020, Airbus SE (Airbus) reached final agreements with the French Parquet National Financier (PNF), the U.K.’s Serious Fraud Office (SFO) and the U.S. Department of Justice (DoJ) in order to resolve...more
2/12/2020
/ Airbus ,
Aviation Industry ,
Bribery ,
Corruption ,
Criminal Prosecution ,
Defense Sector ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Enforcement Actions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Government Officials ,
ITAR ,
Military Contracts ,
National Security ,
Penalties ,
Popular ,
Serious Fraud Office (SFO) ,
Settlement Agreements ,
UK ,
White Collar Crimes
FOURTH QUARTER 2019 -
- Congress closes the year by passing new sanctions against China over human rights concerns, while OFAC clarifies the scope of recent actions against Chinese shipping companies.
- In the wake of...more
1/15/2020
/ AML/CFT ,
China ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
Exxon Mobil ,
Human Rights ,
Iran ,
Iran Sanctions ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Sanctions ,
Voluntary Disclosure
In 2019, the overall number of corporate enforcement actions was slightly higher than in 2018, with twenty-five actions brought, compared to twenty-four in 2018. The number of individuals charged, using our parameters,...more
It is now time for foreign private issuers to prepare their annual reports on Form 20-F. For companies with a calendar year-end, the Form 20-F must be filed with the U.S. Securities and Exchange Commission (the SEC) by April...more
1/2/2020
/ Annual Reports ,
Anti-Money Laundering ,
Audit Reports ,
Disclosure Requirements ,
EBITDA ,
European Commission ,
Foreign Private Issuers ,
Form 20-F ,
Helms-Burton Act ,
IFRS ,
Libor ,
Non-GAAP Financial Measures ,
SEC Comment Letter Process ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
UK Brexit ,
XBRL Filing Requirements
This quarter, the U.S. acted pursuant to statute to punish Russia for its alleged role in the chemical weapons attack on Sergei Skipal and targeted a handful of individuals and entities for certain other malign activities....more
10/21/2019
/ AML/CFT ,
Anti-Corruption ,
CAATSA ,
Criminal Conspiracy ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
Exports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Trump Administration
SECOND QUARTER 2019 –
- US extends sanctions to encompass Iranian metals industries and other targets; Iran announces breach of nuclear accord after EU is unable to offset economic impact of renewed US sanctions.
-...more
Recent Trends And Patterns In FCPA Enforcement -
Although the DOJ and SEC brought a relatively low number of FCPA enforcement actions in the first half of 2019, an unusually large portion of those enforcement actions...more
7/5/2019
/ Anti-Bribery ,
Books & Records ,
CFTC ,
Compliance ,
Corporate Misconduct ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Audit Functions ,
Internal Controls ,
Internal Investigations ,
Non-Prosecution Agreements ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
UK ,
White Collar Crimes
In this quarter, OFAC lifted sanctions on Rusal and other companies following divestment by Oleg Deripaska. Meanwhile, as Venezuela descends into economic and political crisis, the US targeted PdVSA and others to hasten...more
5/10/2019
/ Counter-Terrorist ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Policy ,
Helms-Burton Act ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Relations ,
Trump Administration ,
Venezuela
Closing out 2018, OFAC announced its plan to lift sanctions against United Co. Rusal and others, despite bi-partisan opposition from Congress. Simultaneously, OFAC continued to target Russia’s defense and intelligence sectors...more
1/23/2019
/ Counter-Terrorist ,
Drug Trafficking ,
Economic Sanctions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Magnitsky Act ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trafficking ,
Trump Administration ,
Venezuela