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Office of Foreign Assets Control (OFAC) Criminal Liability

Bracewell LLP

Trump Administration Efforts to Eliminate Cartels Pose Heightened Risk for Financial Institutions

Bracewell LLP on

As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more

Woods Rogers

Designating Cartels as Terrorists: Potential Impact on U.S. Businesses

Woods Rogers on

On his first day in office, President Trump signed an executive order (EO 14157) that sets in motion the designation of certain cartels and transnational crime gangs as terrorist organizations. The President declared a...more

The Volkov Law Group

The Coming Corporate Sanctions Enforcement Storm (Part I of II)

The Volkov Law Group on

There are some things you learn best in calm, and some in storm.  Willa Cather I know I sound like a broken record.  The Justice Department’s white collar criminal enforcement  has been trending down over the last few...more

Oberheiden P.C.

National Security in the Age of Blockchain

Oberheiden P.C. on

Blockchain presents unprecedented challenges around national security. This is true not only for the federal government, but also for businesses in the private sector. From cross-border transactions involving cryptocurrency...more

A&O Shearman

Sanctions Risk: Drafting Contracts to Avoid ‘Double Jeopardy’

A&O Shearman on

In the recent case of Lamesa Investments Ltd v Cynergy Bank Ltd [2019] EWHC 1877 (Comm), the High Court upheld the bank’s attempt to avoid a common banking dilemma: the ‘double jeopardy’ of being contractually liable to make...more

BCLP

A Delicate Balance

BCLP on

How should we approach competing sanctions risks? Among the numerous regulatory compliance risks faced by financial institutions, economic and trade sanctions risks commonly receive a great deal of attention....more

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