This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year.
Throughout 2024, enforcement of international trade laws continued to gather pace...more
3/14/2025
/ Arms Export Control Act ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Compliance ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Enforcement Actions ,
Enforcement Priorities ,
EU ,
EU Directive ,
Export Controls ,
International Trade ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Russia ,
Sanction Violations ,
Tariffs ,
Trump Administration ,
U.S. Treasury ,
UK
Key Takeaways:
The U.S. Supreme Court unanimously held that a party cannot establish the U.S. commercial nexus required to invoke the FSIA’s expropriation exception by alleging a foreign state expropriated property in...more
3/13/2025
/ Commercial Litigation ,
Expropriation ,
Foreign Governments ,
Foreign Sovereign Immunities Act of 1976 (FSIA) ,
International Jurisdiction ,
Jurisdiction ,
Litigation Strategies ,
Popular ,
Republic of Hungary v Simon ,
SCOTUS ,
Statutory Interpretation ,
United States
This is the fifth in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more
This is the fifth in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more
This is the second in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more
1/24/2025
/ Anti-Corruption ,
Australia ,
China ,
Clawbacks ,
Compliance ,
Corporate Counsel ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Draft Guidance ,
Enforcement Actions ,
EU ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
UK ,
Whistleblower Awards ,
Whistleblowers
On December 3, 2024, the U.S. Supreme Court heard oral argument in Hungary v. Simon. As discussed in a previous client alert, the case concerns whether the U.S. Court of Appeals for the D.C. Circuit correctly allowed...more
The Department of the Treasury's Office of Foreign Assets Control (“OFAC”) was active in October and November 2024. After issuing an Updated Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors on...more
On October 22, 2024, the U.S. Court of Appeals for the Second Circuit determined that common-law foreign sovereign immunity does not protect Halkbank, a commercial bank, majority-owned by Turkey, from criminal prosecution for...more
On October 21, 2024, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) issued an Updated Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors (“Updated Advisory”). OFAC...more
10/30/2024
/ Best Practices ,
Capital Markets ,
Environmental Policies ,
Fixed Price ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Regulatory Requirements ,
Sanctions ,
Stakeholder Engagement ,
Transparency ,
Vessels
Since 2010, Simon v. Republic of Hungary has ascended and descended the judicial ladder as federal courts have considered how to interpret and apply the “expropriation exception” of the Foreign Sovereign Immunities Act...more
On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50 (the “Act”). By doing so, the statute of limitations (“SoL”) for violations, both criminal and civil, of IEEPA...more
On the heels of a nationwide sweep in June 2024, in which almost 200 defendants who allegedly committed over $2.7 billion in health care fraud were charged by the U.S. Department of Justice (“DOJ”) Health Care Fraud Unit...more
The government had another busy year in 2023, investigating and prosecuting healthcare fraud cases on multiple fronts. Contending with the enormous healthcare crises of the now-concluded COVID-19 pandemic and the ongoing...more
7/3/2024
/ Anti-Corruption ,
BlackRock ,
Congressional Investigations & Hearings ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Educational Institutions ,
Enforcement ,
Enforcement Actions ,
Export Controls ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Healthcare Fraud ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Tennessee
Throughout 2023 and early 2024, we continue to witness deepening geopolitical and economic divides globally. The U.S. and its allies (most significantly the EU and the G7), spurred on by Russia’s war in Ukraine, continue to...more
5/8/2024
/ China ,
Department of Justice (DOJ) ,
EU ,
G7 ,
Geopolitical Risks ,
International Trade ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
Trade Relations ,
Ukraine
On April 12, 2024, in coordination with the United Kingdom, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two new Determinations (collectively, the “Determinations”) that together prohibit...more
This is the tenth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. Our previous post, "Health Care Fraud Enforcement in 2024," can be found here....more
4/18/2024
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
US Trade Policies ,
White Collar Crimes
On December 22, 2023, President Biden issued a new Executive Order affecting foreign financial institutions and those importing certain goods into the U.S.
In addition, OFAC provided related new and revised FAQs, as well...more
The U.S. Congress has passed the Foreign Extortion Prevention Act (“FEPA”), as part of the National Defense Authorization Act for Fiscal Year 2024 (“NDAA”). On December 14, 2023, the measure was sent to President Biden, who...more
U.S. authorities have been active in November 2023, reinforcing and expanding sanctions targeting Russia's war effort in Ukraine. Multiple agencies added sanctions targeting entities involved in Russia's military supply...more
On October 12, 2023, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) published a Maritime Oil Industry Advisory (“Advisory”)—together with the so-called Price Cap Coalition (“Coalition”), consisting...more
On July 26, 2023, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of the Treasury’s Office of...more
8/3/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Crimes ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure
In Yegiazaryan v. Smagin, the Supreme Court of the United States built upon its decision in RJR Nabisco, Inc. v. European Community, which concerned whether the Racketeer Influenced and Corrupt Organizations Act (“RICO”) ...more