News & Analysis as of

Policies and Procedures Economic Sanctions

Perkins Coie

DOJ Signals Renewed Prioritization of Corporate Enforcement with New Policies Regarding Voluntary Disclosure, Monitors, &...

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On May 12, 2025, Matthew R. Galeotti, the head of the DOJ’s Criminal Division, gave a speech at SIFMA’s Money Laundering and Financial Crimes Conference that previewed subsequently issued policy changes impacting the Criminal...more

Seward & Kissel LLP

Annual Report and Shareholder Meeting Season and Other Recent SEC Developments

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This memorandum summarizes key U.S. Securities and Exchange Commission (“SEC”) and stock exchange regulatory filing deadlines, new disclosure requirements and general tips and guidance for both U.S. domestic issuers and for...more

BakerHostetler

[Event] Protecting the International Project from Catastrophe - November 12th, Houston, TX

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Avoiding Risk and Responding to It - You are cordially invited to a panel discussion with industry leaders from the energy sector, hosted by BakerHostetler's Energy, International Trade and International Arbitration and...more

Proskauer - Regulatory & Compliance

Sanctions Considerations for Private Equity Firms – a few practical tips

Private equity firms could face significant sanctions risks when doing business with entities connected to sanctioned jurisdictions (such as Russia)...more

Foley Hoag LLP

OFAC Publishes Both Interim Final Rule Extending Recordkeeping Requirements and Comment Request Regarding its Information...

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OFAC issued an interim final rule extending OFAC’s recordkeeping requirements from 5 years to 10 years, to comport with the corresponding statute of limitations extension. OFAC also published a request for public comment...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - June 2024 - New Legislation Extends Statute of Limitations for Sanctions Violations

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Venable LLP

Nonprofits Operating Abroad: Five Key Compliance Strategies

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With the current state of the world and heightened scrutiny of the nonprofit sector, it is critical that nongovernmental organizations (NGOs) with international reach routinely assess the effectiveness of their trade...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

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The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

Davis Wright Tremaine LLP

FINRA’s 2024 Annual Regulatory Oversight Report: Select Observations

FINRA recently published its 90-page 2024 Annual Regulatory Oversight Report (Report) providing member firms with insight into six primary topics: Financial Crimes, Crypto Asset Development, Firm Operations, Communications...more

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part II)

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In our prior update (published November 29), we provided the first five steps in our twelve-step program for international compliance. These steps are intended to help companies identify international regulatory risk inherent...more

Oberheiden P.C.

OFAC Compliance: Developing and Implementing an Effective Sanctions Compliance Program

Oberheiden P.C. on

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

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

Conyers

Regulatory & Risk Advisory Review: Cayman Islands – May to July 2023

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Welcome to the second instalment of our Cayman Islands Regulatory & Risk Advisory Review. As we cover in this issue, there have been a number of exciting recent developments, including news from the Financial Action Task...more

Bass, Berry & Sims PLC

Tri-Seal Compliance Note on Voluntary Self-Disclosure Released by Departments of Commerce, Justice, and Treasury

On July 26, the Department of Commerce, Department of the Treasury, and Department of Justice released a Tri-Seal Compliance Note (July Note) providing guidance on voluntary self-disclosure of potential violations of U.S....more

Torres Trade Law, PLLC

Trade Alert: Justice, Commerce, and Treasury Departments Issue a Tri-Seal Compliance Note on Voluntary Self-Disclosures

Torres Trade Law, PLLC on

On July 26, 2023, the Department of Justice (“DOJ”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published their second...more

Faegre Drinker Biddle & Reath LLP

16 “At One Blow” – The SEC Sanctions for Recordkeeping Failures

On September 27, 2022, the SEC announced that it had sanctioned 15 Broker-Dealers and one affiliated RIA for widespread recordkeeping violations of Section 17(a)(1) of the Exchange Act and Rule 17a-4(b)(4) thereunder...more

Ankura

A Revived Nuclear Deal with Iran will Change the Sanctions Landscape

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As of August 29, there is renewed optimism that the EU, the US, and Iran are on the verge of reviving the Joint Comprehensive Plan Of Action (JCPOA) to limit Iran’s ability to develop nuclear weapons in exchange for a lifting...more

Ankura

How would a revived US-Iran nuclear deal change the sanctions landscape?

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Talks between the U.S. and Iran to revitalize the nuclear deal may have stalled but they are far from dead. There is still optimism that the agreement to limit Iran’s ability to make weapons-grade uranium, in return for a...more

American Conference Institute (ACI)

Corporate Compliance and Enforcement Hot Topics with IBM VP, Una Dean

Una Dean sits down for an exclusive video interview for ACI Insights with Rebecca Hughes Parker, Editor-in-Chris of Anti-Corruption Report. Una speaks about the compliance challenges in today’s environment including,...more

American Conference Institute (ACI)

[Event] U.S. Export & Reexport Compliance For Canadian Operations - January 26th - 27th, Toronto, ON, Canada

The Canadian Institute’s 11th Annual Forum on U.S. Export & Re-Export Compliance for Canadian Operations will take place in Toronto on January 25–27! IN-PERSON and LIVESTREAM options available. Over the last decade, this...more

Thomas Fox - Compliance Evangelist

The Memoirs of Sherlock Holmes – The Stock-Brokers Clerk and Foundational Code of Conduct

This week, we return to Sherlock Holmes-themed blog posts. We finished the review of The Adventures of Sherlock Holmes and now move on to The Memoirs of Sherlock Holmes. Today we move on to The Adventure of the Stock-Brokers...more

K2 Integrity

China Emerging as an Increasing Driver of Global Illicit Finance Risk

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Growing Chinese illicit finance threats, vulnerabilities, and exposure are combining to increase illicit financing risk in the international financial system, judging from a series of recent advisories, sanctions actions,...more

Robins Kaplan LLP

Financial Daily Dose 11.04.2019 | Top Story: Feds Probe Under Armour Accounting Practices

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Federal authorities have been looking into Under Armour’s accounting practices for the better part of the past two years, a revelation that sent company shares reeling in premarket trading this morning....more

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