In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more
2/16/2021
/ China ,
Corporate Counsel ,
Cuban Assets Control Regulations (CACR) ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Financial Institutions (FFI) ,
Iran Sanctions ,
Maritime Transport ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Pentagon ,
Pipelines ,
Popular ,
Ransomware ,
Russia ,
SDN List ,
Trump Administration
On January 28, 2021, Transparency International (TI) published its annual Corruption Perceptions Index (CPI) for 2020. As with previous years’ indexes, the CPI 2020 demonstrates that many regions, including the Asia-Pacific...more
In our Quarterly Review, we bring you important UK developments relating to business crime, investigations, and regulatory enforcement from the last three months. Please contact us if you would like to discuss any of these...more
12/15/2020
/ Anti-Corruption ,
Bribery ,
British Airways ,
Criminal Investigations ,
Deferred Prosecution Agreements ,
Financial Conduct Authority (FCA) ,
FSCS ,
General Data Protection Regulation (GDPR) ,
Life Sciences ,
Medicines and Healthcare Products Regulatory Agency (MHRA) ,
Memorandum of Understanding ,
Modern Slavery Act ,
National Crime Agency (NCA) ,
Office of Financial Sanctions Implementation (OFSI) ,
Popular ,
Serious Fraud Office (SFO) ,
Task Force on Climate-related Financial Disclosures (TCFD) ,
Trafficking ,
UK ,
UK Bribery Act
On October 30, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published an advisory highlighting potential sanctions risks arising from dealings in “high-value artwork” (with “particular...more
On October 20, 2020, the U.S. Department of State (“State”) broadened, yet again, the scope of sanctions applicable to Russian energy export pipeline projects, most notably the Nord Stream 2 pipeline, a nearly finished...more
On Wednesday, October 14, 2020, the U.S. Department of State (“State”) submitted a report to the U.S. Congress, as required under section 5(a) of the Hong Kong Autonomy Act (“HKAA”), identifying foreign persons materially...more
10/19/2020
/ China ,
Coronavirus/COVID-19 ,
Foreign Financial Institutions (FFI) ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
SDN List ,
Trump Administration ,
U.S. Treasury ,
US Department of State
On Thursday, October 8, 2020, U.S. Secretary of the Treasury Steven Mnuchin identified the Iranian financial sector as subject to the sectoral sanctions of Executive Order (“E.O.”) 13902, escalating the formidable Trump...more
On September 17, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) reached a $894,111 settlement with Comtech Telecommunications Corp. (“Comtech”) and its subsidiary Comtech EF Data Corp. (“EF...more
In our Quarterly Review, we bring you important UK developments relating to business crime, investigations and regulatory enforcement from the last three months.
We commented last month that the scale of the impact of the...more
9/24/2020
/ Airbus ,
Bribery ,
Corruption ,
DPA ,
Enforcement ,
Espionage ,
Financial Conduct Authority (FCA) ,
Fraud ,
Global Human Rights Sanctions Regime ,
HMRC ,
Investigations ,
Money Laundering ,
National Economic Crime Center (NECC) ,
Popular ,
Regulatory Standards ,
Sanctions ,
Sanctions and Anti-Money Laundering Act 2018 (SAMLA) ,
Serious Fraud Office (SFO) ,
UK
Much of the world’s focus is on the COVID-19 pandemic, and rightfully so, but sanctions regulators also have their gazes fixed on another issue: the maritime industry. On May 14 2020, we saw the U.S. Departments of State and...more
8/7/2020
/ Charter ,
Coast Guard ,
Compliance ,
Cryptocurrency ,
Customs and Border Protection ,
Cyber Attacks ,
Due Diligence ,
Economic Sanctions ,
Exports ,
Imports ,
Insurance Industry ,
Maritime Transport ,
New Guidance ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Ports ,
Risk Assessment ,
Risk Management ,
Risk Mitigation ,
Sanction Violations ,
Shipping ,
U.S. Treasury ,
UK ,
Unions ,
Vessels
Given the magnitude of current events gripping the country and the world, many otherwise noteworthy governmental actions are passing largely unnoticed. One such under-the-radar action occurred on July 22, 2020, when the U.S....more
As the new crown virus is spreading and there have been many demonstrations that "blacks are also fate," the US Congress has increased its work during the election year, threatening to strengthen sanctions against China and...more
The Court of Appeal, in Lamesa Investments Ltd v Cynergy Bank Ltd [2020] EWCA Civ 281, has found that a party in an English law governed “Tier 2 Capital” subordinated facility agreement with contractual language addressing...more
Earlier this week, on July 15, 2020, U.S. Secretary of State Mike Pompeo paved the way for enhanced sanctions on the Russian Nord Stream 2 and TurkStream projects by announcing that the Trump Administration is removing an...more
Amid the COVID-19 pandemic and Black Lives Matter demonstrations, the U.S. Congress has stepped up its election year efforts by threatening heightened sanctions on China and Russia. The latest such bill, the Hong Kong...more
7/10/2020
/ Autonomy ,
China ,
Coronavirus/COVID-19 ,
Hong Kong ,
Office of Foreign Assets Control (OFAC) ,
Protests ,
Russia ,
Sanctions ,
SDN List ,
Secretary of State ,
Trump Administration
In our Quarterly Review, we bring you important UK developments relating to Business Crime, Investigations and Regulatory Enforcement from the last three months. Please contact us if you would like to discuss any of these...more
6/23/2020
/ Bring Your Own Device (BYOD) ,
Coronavirus/COVID-19 ,
Corporate Crimes ,
Cybersecurity ,
EU ,
Financial Conduct Authority (FCA) ,
NCAs ,
NCSC ,
Office of Financial Sanctions Implementation (OFSI) ,
Popular ,
Serious Fraud Office (SFO) ,
UK ,
Unexplained Wealth Orders (UWOs)
On June 5, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued four new frequently asked questions (“FAQs”) that define key terms used in secondary sanctions added to the Iran sanctions...more
The United States has for decades utilized its economic clout to pursue sanctions against rogue governments and regimes, terrorists, narcotics traffickers, and human rights abusers. Now, with roughly half a year left in his...more
It’s no secret that Iran has been one of the hardest hit countries by COVID-19 (commonly referred to as the “coronavirus”). As in other countries, this outbreak has strained Iran’s healthcare system and has instigated a surge...more
On February 18, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) added Rosneft Trading S.A. (“Rosneft Trading”) and its president to the agency’s List of Specially Designated Nationals and...more
Over the past few days, we here at MoFo’s National Security Practice Group have outlined the extraordinary pace of activity that the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) maintained in 2019 as...more
As we mentioned in the first part of our U.S. Sanctions Year in Review series, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) had an extraordinarily busy year in 2019, and its enforcement activity...more
As we enter 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) may need time to catch its breath after an exceptionally busy year. 2019 showed us that the Trump Administration continues to rely on...more
On 17 January 2020, the UK’s Serious Fraud Office (the “SFO”) released guidance on evaluating compliance programmes (the “SFO Guidance”). This is the first time the SFO has issued guidance on how it will assess the...more
On 10 January 2020, updates to the UK anti-money laundering and counter-terrorist financing (together “AML”) laws come into force that bring the UK in line with international standards set by the Financial Action Task Force...more