This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more
The Treasury Department’s Office of Foreign Asset Control continues to focus enforcement activities on digital currency companies. This focus is likely to increase given recent comments by Janet Yellen, the head of the...more
Shortly before the end of his term, the Trump Administration made changes to the List of State Sponsors of Terrorism, removing Sudan and putting Cuba back on. What do the changes mean for Sudan? With the sanctions...more
In an increasingly integrated global economy, and as businesses shift to online sales and a broader client base, it is important to have a clear understanding of, among other things, the U.S. sanctions in place, and the...more
BIS has restricted Cuba’s access to commercial aircraft and other goods, lowered de minimis for foreign items containing US content to 10%, and restricted the temporary sojourn by aircraft in Iran, Syria, Sudan, and North...more
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more
Headlines from the final months of 2017 included the signing of a new executive order with global anti-corruption implications; new guidance on the Trump Administration’s approach to Russia sanctions under CAATSA; tightening...more
Sanctions compliance is challenging because of the changing nature of sanctions regulations and individuals identified as Specially Designated Nationals. With each new administration, foreign policy priorities are usually...more
The Trump Administration has been active on the sanctions front as a means of asserting United States foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late,...more
Recently, many revisions to U.S. sanction programs (both implemented and under consideration) have been the topic of much public discussion. Often, the legal status or these revisions may be difficult to determine....more
ANTICORRUPTION DEVELOPMENTS - U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations - On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation into...more
A comprehensive understanding of the constantly evolving layers that make up federal anti-corruption statutes, sanctions regulations and export control restrictions is imperative for both the pharmaceutical and health care...more
Sanctions: Will the Trump Administration Stay the Course? President Trump made many statements during the campaign regarding actions he plans to take to reverse Obama administration sanctions policies. These included...more
Overview of US and EU Trade Sanctions - Following is a summary of the current US and EU sanctions that restrict trade with and/or investment in certain countries, “Specially Designated Nationals” (SDNs) and “Blocked...more
As if to provide a not-too-subtle reminder to insurers of the applicability of U.S. trade sanctions to their businesses, the Treasury Department’s Office of Foreign Asset Control (OFAC) announced on August 6, that a New...more
The U.S. Department of Commerce’s Office of Foreign Assets Control (OFAC) announced that Navigators Insurance Company, which is headquartered in New York and specializes in marine insurance and related lines of business,...more