This update addresses the full implementation of the price cap policy for crude oil and petroleum products of Russian origin by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). On Feb. 3, OFAC...more
Executive Summary - The North Korean threat to the crypto ecosystem is the highest form of immediate risk to the crypto-economy driven by a regime that seeks to profit from its misuse to reinforce its regime and fuel all its...more
Editor’s Note: On August 17, 2022, The Electronic Discovery Reference Model (EDRM) under the leadership of Mary Mack and Kaylee Walstad, hosted HaystackID as we collectively shared an educational webcast developed to...more
Originally Published: February 25, 2022 – Updated: May 16, 2022 U.S. economic sanctions against Russian interests continue to build in response to the developing situation between the Russian Federation and Ukraine. Donetsk...more
Originally Published: February 25, 2022 – Updated: March 25, 2022 - U.S. economic sanctions against Russian interests have been building in response to the developing situation between the Russian Federation and Ukraine. ...more
The United States, the United Kingdom, and European Union have led a broad international coalition imposing a sweeping and unprecedented range of economic and financial sanctions against Russia and Belarus in response to...more
Originally Published: February 25, 2022 – Updated: March 8, 2022 U.S. economic sanctions against Russian interests have been building in response to the developing situation between the Russian Federation and Ukraine....more
Since the publication of our February 26, 2022, client alert, the United States, United Kingdom and the European Union, among other allied nations, have imposed additional sanctions and export controls on key elements of the...more
After less than a week of a full-scale war between Russia and Ukraine, the post-Cold War global architecture appears irrevocably shattered, as Western nations line up to offer support and military and economic aid to Ukraine...more
Over the past week, the Russian Federation has taken a number of aggressive steps toward Ukraine in furtherance of its ultimate invasion—steps that were immediately condemned by the international community as a blatant...more
China is operating increasingly on a cashless basis. In 2020, cashless transactions amounted to US$49 trillion, accounting for every four out of five payment transactions. The Chinese government has now taken a large leap in...more
Stepping outside of SWIFT - Since its inception more than a decade ago, cryptocurrency has been viewed as a way to supplant traditional global methods of exchanging money. Today, as virtual currencies proliferate,...more
U.S. Developments - Kik Publicizes Response to Possible SEC Enforcement - On January 27, the Wall Street Journal published an article describing the impending legal battle over cryptocurrency Kin and its 2017 ICO. That...more
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
Société Générale (“SocGen”) entered into two deferred prosecution agreements (“DPA”) and agreed to pay $1.34 billion in penalties: $717 million to the Justice Department...more
In this month's edition of our Privacy & Cybersecurity Update, we discuss a Washington state court decision allowing a data breach lawsuit to move forward on a negligence claim, a Ninth Circuit ruling regarding releasing...more
As widely reported, the Spanish police raided last year the Madrid offices of the Chinese state-run Industrial and Commercial Bank of China (“ICBC”), the world’s biggest bank by assets. In the nearly 18 months following that...more
New York Attorney General Announces Record Number of Data Breach Notices in 2016 - On March 21, 2017, the New York Attorney General's Office announced that it received 1,300 reported data breaches in 2016—a 60 percent...more
In an effort to combat an increasing number of fraudulent transfers carried out using its network, SWIFT, the international bank transfer network, announced this month that it is adding new tools and controls designed to...more
Cybersecurity hit the news hard in 2016. The number of high profile, and troubling, cyber incidents increased significantly. The Democratic National Committee and one of Clinton’s top advisor’s being hacked, with leaked...more
On June 7, 2016, the Federal Financial Institutions Examination Council (FFIEC) reminded banks of the cyber risks associated with interbank messaging and wholesale payment networks. FFIEC made its announcement after hackers...more
In February 2016, hackers stole $81 million from the Bangladesh central bank by sending fraudulent messages through the Society for Worldwide Interbank Financial Telecommunication (SWIFT) messaging system. Three months...more
A new set of federal banking regulations are on the horizon aimed at helping financial institutions put in place minimum compliance standards to prevent future cyber-attacks. Bloomberg Law has reported that the Federal...more
Everyone has been in a movie theater when one of the actors approaches that door to the basement behind which strange noises are coming. They reach out to turn the knob and in unison the audience is thinking “Fool, haven’t...more
On Dec. 19, 2014, President Obama issued Executive Order 13685, “Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to the Crimea Region of Ukraine,” to impose sanctions relating to the...more