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Enforcement Actions Cross-Border Transactions

American Conference Institute (ACI)

[Event] 3rd Annual Women in AML & Sanctions Forum - September 16th - 17th, Washington, DC

Your clients are navigating unprecedented sanctions risk. Position yourself at the center of the conversation at ACI’s 3rd Annual Women in AML & Sanctions. This high-impact event brings together leading women across...more

Orrick, Herrington & Sutcliffe LLP

5 Things In-House Counsel Must Know Before DOJ’s Bulk Transfer Rule Enforcement Begins

The Department of Justice’s (DOJ) 90-day grace period for compliance with the Data Security Program (DSP) ends on July 8, 2025, and enforcement is expected to begin. This regulatory regime was created for national security...more

Hogan Lovells

FinCEN invokes new Section 2313a authority against three Mexican financial institutions: The who, what, when, where, why, and...

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The orders represent the first use of new authorities by FinCEN. U.S. based financial institutions that conduct funds transfers with the designated Mexican institutions will be subject to significant compliance obligations,...more

Baker Donelson

Digital Marketing Meets DOJ Oversight: What Businesses with Digital Campaigns Should Do to Manage AdTech Risks

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With the ease of apps and websites for planning activities, whether it be vacations, business trips, or shopping, we open ourselves to multiple sources of being followed across devices by collecting, analyzing, and sharing...more

Porter Hedges LLP

DOJ Issues New Guidelines Narrowing FCPA Enforcement Scope

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On June 9, 2025, the Department of Justice (DOJ) released updated guidelines governing the enforcement of the Foreign Corrupt Practices Act (FCPA), signaling a more focused and strategic approach to foreign bribery cases. The...more

Katten Muchin Rosenman LLP

Confirming a Negative: CFTC Staff Issue an Advisory Clarifying When Foreign-Organized Entities Are Trading and Brokering Digital...

Derivatives market participants and exchanges can breathe a little easier now that Staff of the Market Participants Division and the Division of Market Oversight of the Commodity Futures Trading Commission (CFTC or...more

McDermott Will & Emery

CFTC Staff Letter 25-14: What Is a “U.S. Person”?

On May 21, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division and Division of Market Oversight jointly issued Staff Letter 25-14 in response to a request from SCB Limited, a Bahamas-based...more

Jones Day

CFTC Divisions Interpret "U.S. Person" Definition and U.S. Location Versus Foreign Location

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A 2024 CFTC enforcement action settlement that may have introduced a new test for when the Commodity Exchange Act and the agency's regulations apply on a cross-border basis concerned then-CFTC Commissioner and now Acting CFTC...more

Ballard Spahr LLP

FinCEN’s Southwest Border Geographic Targeting Order Faces Challenges in Texas and Southern California

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In March, we wrote about the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issuing a Geographic Targeting Order (GTO) aimed to combat Mexican-based drug cartels. The GTO signals Treasury’s efforts to...more

Blank Rome LLP

Navigating New Compliance Challenges for Financial Institutions and Payment Processors: The U.S. Treasury’s Enhanced Terrorist...

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In a significant move to combat illicit financial activities focused on cartels, the U.S. government has intensified its scrutiny of cross-border payments, particularly those linked to Mexico. This development follows the...more

American Conference Institute (ACI)

[Event] 11th National Conference on CFIUS - April 24th - 25th, Washington, DC

Determine how the new administration will affect CFIUS practitioners and how the committee will continue its enforcement practices at ACI’s 11th National Conference on CFIUS. ​Don’t miss your best opportunity to hear how your...more

A&O Shearman

CJEU imposes limits on the validity of asymmetric EU jurisdiction clauses

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In a decision that may cause some concern, the CJEU has held that asymmetric EU jurisdiction clauses are only valid under EU law if they designate with sufficient precision the alternative jurisdictions in which proceedings...more

Skadden, Arps, Slate, Meagher & Flom LLP

Annual Report Highlights France’s Financial Crime Enforcement and International Cooperation

Ten years after its establishment, France’s National Financial Prosecutor’s Office (Parquet National Financier or PNF) has released its 2024 annual report (Report),1 showcasing a year of consolidation and innovation in the...more

McDermott Will & Emery

Preparing for a New US Administration: Insights and Resources

President Donald Trump has taken office, and organizations can stay ahead of US policy changes and strategic shifts that may impact operations under the new presidential administration. McDermott’s cross-practice team, along...more

Skadden, Arps, Slate, Meagher & Flom LLP

2025 Insights: A First Look at Trump’s Second Term

As we step into a new year, the potential shifts under a second Trump administration loom large. Our 2025 Insights publication analyzes the impacts these changes could have on both U.S. and global business environments,...more

White & Case LLP

The Shadow Financial System

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The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

American Conference Institute (ACI)

[Event] 5th Annual European Forum on Global FDI Reviews - June 11th - 12th, Ixelles, Belgium

Hosted by C5 Group, the 5th Annual European Forum on Global FDI Reviews returns for another exciting year with curated programming that provide sessions on the most pressing issues coming across your desk and strategic...more

Jenner & Block

Client Alert: White House Executive Order Seeks to Protect Americans’ Sensitive Personal Data and US Government-Related Data in...

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On February 28, 2024, President Biden issued Executive Order 14117 on Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern (the EO). The EO empowers...more

American Conference Institute (ACI)

[Event] 10th National Conference on CFIUS - April 11th - 12th, Arlington, VA

Hosted by American Conference Institute, the 10th National Conference on CFIUS returns for another exciting year with curated programming that will provide invaluable insights on repositioning your transaction planning amidst...more

American Conference Institute (ACI)

[Event] New York Forum on Economic Sanctions - December 13th - 14th, New York, NY

Back by popular demand, ACI’s acclaimed 13th Annual New York Forum on Economic Sanctions returns to NYC this December. Regarded as the must attend conference for legal and compliance professionals working for financial...more

American Conference Institute (ACI)

[Event] 5th Conference on U.S.-China Trade Controls - October 12th - 13th, Washington, DC

As the only comprehensive, practical event of its kind in the Unites States, ACI is hosting the highly anticipated 5th Annual U.S.-China Trade Controls Conference, scheduled for October 12–13 in Washington, DC. Considering...more

Oberheiden P.C.

OFAC Compliance: Developing and Implementing an Effective Sanctions Compliance Program

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Financial institutions and companies that are subject to oversight from the Office of Foreign Assets Control (OFAC) need to prioritize compliance. OFAC has become increasingly active in recent years, and it is devoting...more

Latham & Watkins LLP

New CFIUS Developments Signal Heightened Attention on Enforcement: 4 Areas to Watch

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The recent developments signal a renewed vigor to protect US national security. This Client Alert highlights the following recent developments relating to national security investment reviews conducted by the Committee on...more

Lighthouse

An Expert View on the Critical Data Privacy Issues for 2023 and Beyond

Lighthouse on

If there has been any constant in the wave of privacy changes since the enactment of GDPR, it’s been the need to stay vigilant about the impacts of evolving regulations and enforcement globally. From changes to the California...more

American Conference Institute (ACI)

[Event] European Forum on Global Economic Sanctions - June 1st - 2nd, Berlin, Germany

Hosted by C5 Group, the European Forum on Global Economic Sanctions is recognized as Europe's Premier, longstanding gathering for financial institutions and global exporters. The industry across Europe is confronting an...more

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