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Due Diligence Sanctions

Accountancy Forum Newsletter - December 2017

by Reed Smith on

In this edition, we have drafted an article on the recent FRC sanctions and we have also included short summaries of recent cases and items of interest to our target audience. At the end of the newsletter, you will also find...more

FCA sanctions bank and its MLRO for anti-money laundering systems failings

by Allen & Overy LLP on

In this decision report we review the FCA’s action against Sonali Bank (UK) Ltd (Sonali Bank) and its money laundering reporting officer (MLRO), Steven Smith, in connection with failings identified in relation to Sonali...more

EU and UK Sanctions Update: July 2016

by K&L Gates LLP on

Below is a summary of developments since our previous update in May, relating to European Union (“EU”) sanctions on Russia, Iran and other jurisdictions, the impact of Brexit on EU sanctions and recent changes with respect to...more

Investment Industry Regulatory Organization of Canada Securities Enforcement Trends and What’s Ahead for 2016

Securities enforcement activities in Canada are overseen by several agencies, including the Canadian Securities Administrators, the Investment Industry Regulatory Organization of Canada, the Ontario Securities Commission, the...more

Broker, Compliance Officer Fined For AML Failures

by Dorsey & Whitney LLP on

Money laundering continues to be a key focus of regulators. Recently, for example, FINCEN Director Jennifer Shasky Calvery discussed money laundering through real estate transactions. Earlier this year the SEC brought an...more

SEC Affirms Sanctions on Stanford’s CCO

by Burr & Forman on

The SEC recently affirmed its ALJ’s ruling barring Alan Stanford’s former CCO from the industry and ordering monetary penalties of $260,000 together with $591,992 in disgorgement. The Commission held the CCO approved false...more

Australian Anti-Bribery & Compliance Trends

Today we welcome Ted Williams, Partner, Piper Alderman. Ted, can you share some of your background and experience? TW: Thank you, Richard, for the opportunity to engage with your community, and it was a pleasure to...more

New EU Securitisation Regulation: Moving in the Right Direction

by Dechert LLP on

The European Commission published a draft regulation on a European framework for simple, transparent and standardised securitisation on 30 September 2015 (the “Draft Regulation”). The Draft Regulation aims to achieve a better...more

The 5 Most Common AML Compliance Program Deficiencies

by Michael Volkov on

Anti-money laundering compliance is a very difficult task. The number of risks is exponential. AML compliance officers have an innovative and rich history of compliance techniques and strategies. In the end, AML compliance...more

Iran – Don’t Forget the General License!

by Baker Donelson on

Iran entered into a historic nuclear agreement with the U.S. and other world powers on July 14th 2015. The agreement will allow the licensing of the export, re-export, sale, lease or transfer to Iran of commercial passenger...more

The Foreign Corrupt Practices Act: At a Glance

by Locke Lord LLP on

In this issue: - FCPA AT A GLANCE - THE ANTI-BRIBERY PROVISIONS OF THE FCPA - TO WHOM THE ANTI-BRIBERY PROVISIONS APPLY - THE PAYMENT ELEMENT - THE CORRUPT INTENT ELEMENT - WHO IS A...more

Export Control Laws for the General Counsel

by Williams Mullen on

You are the chief legal officer of a U.S. company. Your CEO walks into your office and announces that your company is about to conclude its first international sale. In addition, the company has just appointed distributors in...more

Doing Business with Russia Following Sanctions: What PE Firms Need to Know

by Dechert LLP on

It has now been over a year since the United States and the European Union began imposing sanctions on Russian and Ukrainian individuals and entities in connection with the situation in Ukraine. The sanctions have major...more

FinCEN Imposes Significant Fines In a Warning to Adhere to Due Diligence Requirements

by BakerHostetler on

In its recent decision to impose $20 million in sanctions upon Oppenheimer and Co. for the company’s failure to maintain internal controls to promote enforcement of the Bank Secrecy Act (BSA), FinCEN revealed the emphasis it...more

Sharing the Spotlight: M&A Due Diligence

by Michael Volkov on

Everyone likes to talk about the importance of due diligence. A whole new due diligence industry has grown, starting with initial anti-money laundering requirements and stretching into corruption and sanctions issues....more

OFAC Makes Important Update to Ownership/Control Guidance

On August 13, 2014, the Office of Foreign Assets Control (OFAC) issued new guidance on ownership/control for determining blocked parties. This represented the first significant update on this topic since February 14, 2008,...more

New Sanctions Guidance Increases Due Diligence Burden on Companies

On August 13, 2014, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published guidance (“Revised Guidance”) that revises its 2008 guidance regarding how to treat entities that are owned or...more

Practical Guidance for Dealing with OFAC’s Recently Released Ukraine Related Sanctions Regulations and the EU’s Ukraine Sanctions

by Dorsey & Whitney LLP on

On May 8, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued regulations to implement three Executive Orders issued by President Obama in March regarding the situation in Ukraine. The...more

New Item for Diligence Review Process: OFAC’s Foreign Sanctions Evaders List

On February 6, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published notice that it was listing 11 named parties as “Foreign Sanctions Evaders,” pursuant to Executive Order 13608 (May 1, 2012)...more

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