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Penalties Economic Sanctions

Adams and Reese LLP

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

Sheppard Mullin Richter & Hampton LLP

Walking the Tightrope: EU’s Sanctions Enforcement Directive Puts Violators on Notice

In a bold move to tighten its sanctions enforcement, the EU rolled out Directive 2024/1226, establishing minimum rules for defining criminal offenses and penalties related to the violation of EU sanctions. Effective May 19,...more

White & Case LLP

EU establishes harmonized enforcement and penalties for sanctions violations

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The EU has adopted a new directive which establishes EU-wide rules for defining criminal offences and penalties related to the violation of EU sanctions. A stricter regulatory environment and closer scrutiny is expected as...more

Mayer Brown

Teeth Can Bite: Towards Harmonized Rules on EU Sanctions Criminal Enforcement

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On March 12, 2023, the European Parliament ("EP") formally endorsed the adoption of a Directive defining criminal offences and penalties for the violation of European Union ("EU") restrictive measures, colloquially known as...more

Adams and Reese LLP

Beyond Borders: Navigating Global Business Compliance with the FCPA

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On March 7th, the Department of Justice (DOJ) announced a new whistleblower reward program intended to help prosecutors bring more foreign corruption cases. Under the new program, individuals who report corporate misconduct...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

Walkers

EU sanctions update: Guidance published on the 'No Russia Clause'

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The EU has continued to tighten economic sanctions against Russia in recent months with the introduction of the 12th sanctions package on 18 December 2023 and the 13th sanctions package on 24 February 2024. Of particular...more

K&L Gates LLP

Brussels Regulatory Brief: Winter 2023-2024

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Antitrust and Competition - The European Court of Justice Held Rules Set by Sports Governing Bodies Must Comply With EU Competition Law - On 21 December 2023, the European Court of Justice (ECJ) held in a preliminary ruling...more

Akin Gump Strauss Hauer & Feld LLP

New Executive Order Authorizes the Imposition of Secondary Sanctions on Foreign Financial Institutions Facilitating Russia’s...

Key Points - On December 22, 2023, President Biden issued E.O. 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.” Specifically, E.O. 14114, which amends E.O. 14024 and E.O. 14068,...more

NAVEX

The Subtle but Significant Shift at U.S. Justice Department

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In October, deputy attorney general Lisa Monaco made headlines when she announced a new leniency policy at the U.S. Justice Department for companies that disclose compliance violations discovered during mergers and...more

Foley & Lardner LLP

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

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Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more

Foley & Lardner LLP

International Trade, Enforcement & Compliance Recent Developments Update (October 25, 2023)

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A veritable grab bag of international trade developments to parse this week. Recent developments include increasing FCPA enforcement, a record OFAC economic sanctions penalty, and a large customs penalty for willful failure...more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

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The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

Akerman LLP

The Art of Coming Clean: Agencies Provide Guidance on Voluntary Self-Disclosures of Export Controls and Sanctions Violations

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On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more

WilmerHale

OFSI Issues Updated Guidance Relating to Assessments of due Diligence Conducted in Relation to the “Ownership and Control” Test,...

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The Office of Financial Sanctions Implementation (OFSI) has updated its ‘enforcement and monetary penalties for breaches of financial sanctions’ guidance, which was last updated in June 2022. ...more

Oberheiden P.C.

Recent Developments in BIS Charging Letter Protocols Could Damage Your Company’s Reputation

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The Bureau of Industry and Security (BIS) in the United States Department of Commerce has experienced a surge in recognition and importance over the past year. This Bureau, and particularly the Office of Export Enforcement...more

Dechert LLP

The ESG Climate Change Evolution of Commercial Real Estate Finance: Turning Over New (Green) Leaves

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The Intergovernmental Panel on Climate Change’s Sixth Assessment report, released most recently in spring 2022, sounded the alarm on the current state of the Earth’s climate. Today, with just 1.1 degrees Celsius in warming,...more

Snell & Wilmer

Russia’s Purported Annexation of Ukraine Prompts Expanded Sanctions for Individuals and Entities in Third Countries Supporting...

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On September 30, 2022, the United States instituted new sanctions to address the ongoing Russian-Ukraine conflict. The new sanctions follow the Leaders of the Group of Seven’s (“G7”) statement condemning Russia’s referendum...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

Morrison & Foerster LLP

OFAC 2020 Year In Review

In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more

Foley & Lardner LLP

Brazilian Government Makes the LGPD Effective Imminently

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On August 14, 2018, the Brazilian government approved the Brazilian General Data Protection Law, known as the Lei Geral de Proteção de Dados Pessoais (“LGPD”). Enforcement was set to begin on August 15, 2020 but then, due to...more

Perkins Coie

Hong Kong Autonomy Act Signals Significant Shift in US-Hong Kong Relations

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The U.S. government on July 14, 2020, took two significant steps to address the evolving situation in Hong Kong. These were primarily in response to the enactment of the Law of the People's Republic of China on Safeguarding...more

White & Case LLP

OFSI imposes first multi million pound penalty for UK sanctions breach

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The UK sanctions authority, the Office of Financial Sanctions Implementation (OFSI), has announced its first multi million pound fine since its establishment in 2016.  The fine confirms OFSI’s increasing enforcement activity...more

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