On 1 April 2025, the UK government confirmed that the Foreign Influence Registration Scheme (FIRS) — which was established under the National Security Act 2023 — will come into force from 1 July 2025. The UK government has...more
On his first day in office, President Trump signed Executive Order 14157 calling for the designation of certain cartels and transnational criminal organizations (TCOs) as foreign terrorist organizations (FTOs) or specially...more
The European Union (EU) has reaffirmed its sanctions policy toward Russia by implementing two rounds of restrictive measures that are intended to further intensify pressure on Russia’s government and economy. Specifically,...more
3/18/2025
/ Asset Freeze ,
Compliance ,
Economic Sanctions ,
Energy Sector ,
Enforcement Actions ,
EU ,
European Commission ,
Export Bans ,
Export Controls ,
Financial Institutions ,
International Trade ,
National Security ,
Oil & Gas ,
Regulatory Agenda ,
Russia ,
UK ,
Ukraine
Key Points -
- In 2024, securities litigation remained consistent with historical averages, with a slight increase in core filings and cases related to COVID-19 and artificial intelligence.
- The U.S. Supreme Court had an...more
2/27/2025
/ Acquisitions ,
Automotive Industry ,
Class Action ,
Class Certification ,
Corporate Counsel ,
Digital Assets ,
Filing Requirements ,
Item 303 ,
Macquarie Infrastructure Corp v Moab Partners LP ,
Mergers ,
Popular ,
Private Securities Litigation Reform Act of 1995 ,
PSLRA ,
Real Estate Market ,
Rule 10b-5 ,
SEC v Jarkesy ,
Securities Fraud ,
Securities Litigation ,
Securities Regulation ,
Technology Sector
The future of international sanctions on Russia is not settled. Whilst the representatives of the US and Russia met in Saudi Arabia on 18 February 2025 to discuss possible avenues to peace in Ukraine, the foreign ministers of...more
2/25/2025
/ Anti-Money Laundering ,
Compliance ,
Cryptocurrency ,
Enforcement Actions ,
EU ,
Financial Institutions ,
Financial Services Industry ,
Popular ,
Russia ,
Sanctions ,
UK
On February 10, 2025, President Donald Trump signed an executive order directing the U.S. attorney general, Pam Bondi, to pause Foreign Corrupt Practices Act (FCPA) actions for 180 days until she issues revised FCPA...more
2/13/2025
/ Anti-Corruption ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
Key Points -
- During its 2024 term, the U.S. Supreme Court is poised to provide important guidance on the Private Securities Litigation Reform Act’s (PSLRA’s) particularity requirement in NVIDIA Corp. v. E. Ohman J:or...more
12/6/2024
/ Acquisitions ,
Automotive Industry ,
Class Action ,
Cybersecurity ,
Data Privacy ,
Digital Assets ,
E-Commerce ,
Electric Vehicles ,
Energy Sector ,
Financial Institutions ,
Financial Services Industry ,
Healthcare ,
Investment Adviser ,
Life Sciences ,
Mergers ,
NVIDIA ,
Nvidia Corp v E Ohman J or Fonder AB ,
Pharmaceutical Industry ,
PSLRA ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Litigation ,
Securities Regulation ,
Technology Sector ,
Trading Platforms
On 6 November 2024, the UK government published its guidance on the new ‘failure to prevent fraud’ offence, which was introduced in the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023).1 We covered the details...more
The past weeks and months have brought about tremendous political change in the West, as we move toward a new U.S. administration, a new College of Commissioners in Brussels and a new Polish presidency of the Council of the...more
11/13/2024
/ Capital Markets ,
CFIUS ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Export Controls ,
Extraterritoriality Rules ,
Financial Institutions ,
Middle East ,
National Security ,
Regulatory Requirements ,
Russia ,
Sanctions ,
Tariffs ,
Trump Administration ,
UK ,
Ukraine ,
US Trade Policies ,
Whistleblowers
What is the EU Corporate Sustainability Due Diligence Directive?
The Corporate Sustainability Due Diligence Directive (CS3D) is a pivotal European Union directive that mandates human rights and environmental due diligence...more
11/5/2024
/ Climate Change ,
Corporate Governance ,
Corporate Social Responsibility ,
Due Diligence ,
Environmental Policies ,
Environmental Social & Governance (ESG) ,
EU ,
European Commission ,
Human Rights ,
New Regulations ,
Regulatory Requirements ,
Supply Chain ,
Sustainability
On 27 September 2024, the UK’s financial sanctions regulator, the Office of Financial Sanctions Implementation (OFSI), announced that it had issued its first monetary penalty for a breach of UK financial sanctions imposed...more
On September 23, 2024, the U.S. Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs (ECCP) guidance. First published in 2017, the ECCP sets out factors that DOJ Criminal Division prosecutors...more
On 12 September 2024, the UK government published The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (Regulations) which, among other things, set out the powers of the new Office of Trade...more
9/25/2024
/ Economic Sanctions ,
Enforcement Actions ,
Financial Regulatory Reform ,
International Trade ,
New Legislation ,
New Regulations ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Sanctions ,
Trade Policy ,
UK
When the UK Modern Slavery Act 2015 (Act) came into force, it was considered a landmark legal development globally. The UK was one of the first jurisdictions to introduce a legal requirement concerning transparency in supply...more
9/19/2024
/ Anti-Corruption ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
Human Rights ,
Human Trafficking ,
International Trade ,
Modern Slavery Act ,
Reporting Requirements ,
Supply Chain ,
Transparency ,
UK ,
White Collar Crimes
The UK government introduced a major overhaul of its framework for addressing financial crime — and brought into force numerous significant changes — when the Economic Crime and Corporate Transparency Act 2023 (the Act)...more
9/12/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Corporate Crimes ,
Corporate Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Enforcement Actions ,
EU ,
Failure to Prevent ,
Financial Crimes ,
Fraud ,
Strict Liability ,
UK ,
White Collar Crimes
On 31 July 2024, the UK government broadened its Russian sanctions regime, giving the government express power to impose sanctions on persons who provide financial services, or make available funds, economic resources, goods...more
Russia’s invasion of Ukraine has resulted in unprecedent judicial scrutiny of the UK’s sanctions regulations. While the judgments delivered in many cases have provided companies with needed certainty on some topics, the...more
In Nuctech Warsaw (T-284/24), the EU Court of Justice held that EU subsidiaries can lawfully be required to provide access to email accounts and data held by their overseas parent company. The ruling involved the following...more
8/26/2024
/ Appeals ,
Commercial Litigation ,
Corporate Counsel ,
Corporate Governance ,
Enforcement Actions ,
EU ,
European Commission ,
European Court of Justice (ECJ) ,
Extraterritoriality Rules ,
Foreign Corporations ,
Popular ,
Privacy Laws ,
UK ,
White Collar Crimes
On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more
8/6/2024
/ Anti-Corruption ,
CFTC ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FinCEN ,
Government Agencies ,
Pilot Programs ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
The UK Court of Appeal recently held that the National Crime Agency’s decision not to investigate whether cotton goods manufactured in China and imported to the UK were the product of forced labour was unlawful — a decision...more
7/8/2024
/ Appeals ,
China ,
Corporate Counsel ,
Financial Crimes ,
Financial Institutions ,
Imports ,
International Trade ,
Legislative Agendas ,
National Crime Agency (NCA) ,
Popular ,
Proceeds of Crime Act 2002 (POCA) ,
Supply Chain ,
UK
On June 26, 2024, the U.S. Supreme Court found that the main federal anti-corruption statute proscribing bribes to state and local officials does not criminalize gratuities, which the Court described as “payments made to an...more
7/3/2024
/ Bribery ,
Corruption ,
Fraud ,
Illegal Gratuities ,
Mayors ,
Public Corruption ,
Public Officials ,
Public Servants ,
SCOTUS ,
Snyder v United States ,
Undue Influence Claims
Historically, multinational companies and those lobbying on their behalf mostly concerned themselves with the U.S. and Canadian legal frameworks for lobbying. But more and more jurisdictions are establishing increasingly...more
Below is a summary of recent developments and enforcement trends in the UK white collar crime space in the first quarter of 2024.
I. New Legislation -
The Economic Crime and Corporate Transparency Act 2023 (ECCTA)...more
On March 26, 2024, the French Anti-Corruption Agency (AFA) published a guide on how to engage in corporate sponsorship and charitable donation activities while appropriately mitigating corruption risks (the Guide)...more
5/13/2024
/ AFA ,
Anti-Corruption ,
Charitable Donations ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
EU ,
France ,
Internal Investigations ,
New Guidance ,
Self-Reporting ,
Sponsorship Agreements ,
UK ,
White Collar Crimes
On April 24, 2024, President Joe Biden signed into law a high-profile package of national security legislation (Public Law 118-50). While most press reports focused on the spending elements of the package (appropriating funds...more
5/3/2024
/ Asset Freeze ,
Asset Seizure ,
Economic Sanctions ,
Export Controls ,
International Trade ,
Investors ,
Joe Biden ,
Legislative Agendas ,
National Security ,
New Legislation ,
Russia ,
Ukraine