News & Analysis as of

Foreign Entities Enforcement Actions

Seward & Kissel LLP

DOJ Implements New Data Security Program: Data Transfer Restrictions with a National Security Focus

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Effective as of April 8, 2025, the National Security Division of the U.S. Department of Justice (DOJ) has implemented a Data Security Program (the DSP) to address national security risks associated with the transfer of...more

Holland & Knight LLP

Colleges and Universities Must Report Certain Foreign Gifts and Contracts

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In light of recent enforcement activity, institutions of higher education should review their reporting and disclosure obligations related to foreign entities and individuals under Section 117 of the Higher Education Act (20...more

Holland & Hart LLP

FinCEN EXEMPTS U.S. Companies and U.S. Persons from CTA Reporting Requirements

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The Corporate Transparency Act (together with its implementing regulations, the CTA) is a federal law that went into effect on January 1, 2024. The CTA is aimed at combating financial crimes such as money laundering,...more

Morrison & Foerster LLP

Treasury Department Shifts CTA to Foreign Entities

As we recently reported, the Financial Crimes Enforcement Network (FinCEN) has been chipping away at the CTA, including through a recent notice. Now, Treasury has dramatically changed the CTA landscape with respect to U.S....more

DLA Piper

Recent Settlement Demonstrates DOJ’s Focus on Foreign Entities Misrepresenting Anti-Money Laundering Compliance

DLA Piper on

The US Department of Justice (DOJ) has announced that Wall Street Exchange (WSE), a Dubai-based money exchange service provider, entered into a non-prosecution agreement (NPA) and agreed to pay more than $9.2 million to...more

Kilpatrick

8 Key Takeaways | Part Two -- 2024 Roundup: Key Takeaways from U.S. Sanctions Enforcement Actions and 2025 Predictions

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Throughout 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control ("OFAC") published 12 enforcement actions regarding alleged sanctions violations by foreign and domestic persons and entities....more

Farella Braun + Martel LLP

FTC Enforces Against Non-US Entity, But Is a U.S.-Based Physical Presence a Necessary Predicate?, Nate Garhart

The U.S. is rightfully protective of U.S. consumers, and the Federal Trade Commission (FTC) often takes the role of protecting privacy rights through Section 5 of the FTC Act. The linked article highlights such enforcement...more

Gardner Law

FDA Issues Numerous Warning Letters

Gardner Law on

The U.S. Food and Drug Administration (FDA) uses warning letters to notify manufacturers that they have violated the FDA’s regulations or federal law. Manufacturers that receive warning letters must respond promptly, and they...more

Allen Barron, Inc.

How Does the IRS Use AI to Identify Tax Cheats?

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Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more

K2 Integrity

SEC’s New Cyber Disclosure Rule: Challenges, Consequences, And Compliance

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The U.S. Securities and Exchange Commission’s (SEC) impending cyber disclosure rule, slated to commence on 15 December 2023, underscores an imperative shift towards a more transparent and accountable cybersecurity posture for...more

Akin Gump Strauss Hauer & Feld LLP

Research Security: New NIH Policy Requires Foreign Subrecipients to Share Lab Notebooks & Research Data With the U.S. Prime...

On September 15, 2023, the National Institutes of Health (NIH) moved forward with a controversial new policy requiring foreign subrecipients to provide, at least once per year, copies of lab notebooks, data and documentation...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – July 2023 Update

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July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more

Barnea Jaffa Lande & Co.

ICA Request for Information: Foreign Company Fined

The Israeli Competition Director General recently announced he had reached an agreement with the British pharmaceutical company Leadiant Biosciences. According to the agreement, Leadiant undertook to pay ILS 110,000 to the...more

Pillsbury Winthrop Shaw Pittman LLP

Economic Crime (Transparency and Enforcement) Act Provides Transitional Period

Overseas entities that own or lease UK real estate must register at Companies House by January 31, 2023. Failure to comply with the Act will expose the overseas entity and its officers to criminal sanctions and could...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Government Expands Enforcement Measures To Address Fraud and Money Laundering

On 22 September 2022, the U.K. government introduced the Economic Crime and Corporate Transparency Act 2022. The new bill is currently navigating its way through the U.K. Parliament and is likely to receive royal assent in...more

Alston & Bird

Italian Supervisory Authority Imposes 20 Million EUR Fine on Controller Outside of Europe

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The Italian Garante per la Protezione dei dati Personali (‘Italian SA’) published a decision of February 10, 2022 in which it imposes a 20 million EUR fine on a company outside of Europe for violation of the EU General Data...more

BakerHostetler

[Podcast] The Emerging New Era for Noncompetes and Trade Secrets: Global Reach: Extraterritoriality and DTSA Enforcement Beyond...

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“Global Reach: Extraterritoriality and DTSA Enforcement Beyond the U.S.” is episode three of BakerHostetler's six-part series, "The Emerging New Era for Noncompetes and Trade Secrets.”...more

Cadwalader, Wickersham & Taft LLP

The UK Serious Fraud Office’s Extraterritorial Powers Are Clarified

After three years of uncertainty over the Serious Fraud Office’s (“SFO”) powers to obtain documents  located overseas, the UK Supreme Court has clarified the extraterritorial effect of the legislation facilitating that power...more

Morrison & Foerster LLP

China's "Unreliable Entity List" Will Be In A Dilemma When Multinational Companies Respond To US Sanctions And "Long-Arm...

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China has recently introduced unreliable entity list ("Entity List") regulations to provide a framework for China's upcoming list of economic sanctions. As early as October 2018 and March 2020, China has implemented "blocking...more

Skadden, Arps, Slate, Meagher & Flom LLP

Insights Conversations: DOJ Enforcement Priorities

Former U.S. attorney Jessie K. Liu recently joined Skadden from her role overseeing the U.S. Attorney’s Office in Washington, D.C., which is not only the largest in the country but also home to one of the busiest Civil...more

Ballard Spahr LLP

U.S. Treasury and DOJ Targets “Evil Corp”

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Organization Excels at Niche Branding but Stumbles in Avoiding Enforcement - The first paragraph of the press release sums it up: Today the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) took action...more

Jones Day

UK Draft Bill Addresses Criminal Money Laundering Through Overseas Entities

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The Situation: The purchase of property in the United Kingdom has, for various reasons, become an attractive mechanism by which to launder criminal proceeds through overseas entities. The Solution: A draft bill is...more

Allen Matkins

Did Ethiopian Electric Power Violate California’s Corporate Securities Law?

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Last week, the Securities and Exchange Commission announced a $6.5 million settlement with Ethiopian Electric Power, which was described in the SEC’s order as “a government-owned power utility headquartered in Addis Ababa,...more

Blank Rome LLP

SEC FCPA Enforcement Action against Goodyear and Investigation of Mondelez International Provide Valuable Lessons for U.S....

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Action Item: The Securities and Exchange Commission’s enforcement action against Goodyear Tire & Rubber Company and its investigation of Mondelez International provide key lessons to U.S. companies seeking to acquire foreign...more

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