Events & Publications
- Oct 16, 2020
- Publications
Despite COVID-related challenges, FCPA enforcement by the DOJ and the SEC continued at full speed in the third quarter of 2020. Enforcement activity included three corporate resolutions by the DOJ and four resolutions by the SEC, as…
- Oct 06, 2020
- Publications
Litigation partner Roberto Gonzalez and counsel Rachel Fiorill served as contributing editors and authored two chapters in the International Comparative Legal Guide (ICLG): Sanctions 2021, published by the Global Legal Group Ltd.,…
- Sep 29, 2020
- Publications
U.S. banks and federal savings associations may accept deposits that serve as reserves for stablecoin backed on a 1:1 basis by a single fiat currency in a hosted wallet.
- Aug 31, 2020
- Publications
In a decision that offers greater clarity on what conduct is, and is not, subject to criminal prosecution with regards to sanctions-related violations, the Second Circuit recently upheld the conviction of a former executive of…
- Aug 24, 2020
- Publications
Federal banking agencies, along with FinCEN, recently issued new guidance on BSA/AML enforcement and customer due diligence obligations.
- Aug 05, 2020
- Publications
Litigation partner Roberto Gonzalez, counsel Rachel Fiorill and associate Anand Sithian co-authored an article, "Essentra Case Signals New Sanctions Risks For Non-US Cos.," that appeared in the Expert Analysis section of Law360.
- Jul 23, 2020
- Publications
DOJ and OFAC recently announced parallel sanctions resolutions with Essentra FZE Company Limited, a UAE-based supplier of cigarette products. Essentra FZE received payments in U.S. dollars and UAE Dirham into bank accounts held at a…
- Jul 21, 2020
- Publications
President Trump recently signed the Hong Kong Autonomy Act (HKAA) into law and issued an executive order implementing the HKAA.
- Jun 22, 2020
- Publications
The UK Financial Conduct Authority recently ordered Commerzbank to pay more than £37 million penalty for years of anti-money laundering failures in systems and controls.
- Jun 08, 2020
- Publications
The DOJ’s Criminal Division released updated guidance regarding the manner in which prosecutors evaluate the effectiveness of corporate compliance programs. The guidance makes clear that companies should continuously update their…
Litigation partner Roberto Gonzalez moderated a panel, “Sanctions and Security: What’s New at OFAC in 2020,” as part of the Institute of International Bankers’ two-day virtual seminar.
- May 19, 2020
- Publications
On May 14, 2020, the U.S. Department of State, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the U.S. Coast Guard (collectively, the “Agencies”) issued updated guidance entitled, “Guidance to…
- May 14, 2020
- Publications
On May 6, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced a $257,862 settlement agreement with BIOMIN America, Inc. (“BIOMIN America”), an animal nutrition company based in Overland Park,…
- May 05, 2020
- Publications
The DOJ, Federal Reserve and the New York State Department of Financial Services announced nearly $875 million in penalties against Bank Hapoalim and its Swiss subsidiary.
- May 01, 2020
- Publications
On April 16, 2020, the New York Department of Financial Services (“DFS”) issued a Statement of Charges and Notice of Hearing against Irish pharmaceutical company Mallinckrodt plc and several of its U.S. subsidiaries (collectively,…
- Apr 24, 2020
- Publications
The DOJ, the N.Y. Attorney General and the N.Y. Department of Financial Services (DFS) recently announced an $86 million resolution with Industrial Bank of Korea (IBK) in connection with criminal violations of the Bank Secrecy Act and …
- Mar 25, 2020
- Publications
Under an emergency regulation issued by the NY Department of Financial Services, DFS-regulated banking organizations and mortgage servicers must grant a 90-day forbearance on residential mortgage payments for New York residents who…
- Mar 23, 2020
- Publications
N.Y. Gov. Andrew Cuomo has issued an executive order temporarily deeming the failure of a New York-regulated bank to grant a forbearance to an individual or business in certain circumstances an “unsafe and unsound” business practice.
- Mar 19, 2020
- Publications
The N.Y. Department of Financial Services (DFS) has taken a number of recent steps in response to the COVID-19 pandemic, including granting temporary regulatory relief and filing extensions to regulated entities, and requiring such…
- Mar 16, 2020
- Publications
The U.S. Treasury Department’s Office of Foreign Assets Control has announced a $7,829,640 settlement agreement with Geneva-based Société Internationale de Télécommunications Aéronautiques.
- Mar 13, 2020
- Publications
On February 26, 2020, the U.S. District Court for the District of Connecticut entered a judgment of acquittal for Lawrence Hoskins on all Foreign Corrupt Practices Act (“FCPA”) charges.[1] The ruling partly overturns a jury’s verdict…
- Mar 09, 2020
- Publications
On March 4, 2020, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a consent order assessing a $450,000 civil money penalty against Michael LaFontaine, a former Chief Operational Risk Officer at U.S.…
- Feb 24, 2020
- Publications
On February 21, 2020, Wells Fargo & Company and its subsidiary, Wells Fargo Bank, N.A. (collectively, “Wells Fargo”), entered into resolutions with the Department of Justice (“DOJ”) and the Securities and Exchange Commission (the…
- Jan 31, 2020
- Publications
This memorandum surveys economic sanctions and anti-money laundering (“AML”) developments and trends in 2019 and provides an outlook for the year ahead.
- Jan 28, 2020
- Publications
As the latest chapter in the aftermath of the Wells Fargo fake accounts scandal, the OCC announced enforcement actions against eight former Wells Fargo executives for their roles in the bank’s “systemic sales practices misconduct.”
- Jan 24, 2020
- Publications
In this annual review, we reflect on the most significant anti-corruption and FCPA enforcement and policy trends of 2019 and share our insights on developing U.S. and global anti-corruption efforts in 2020.
- Dec 19, 2019
- Publications
The U.S. Department of Justice’s National Security Division recently announced a revised policy designed to encourage companies, including financial institutions, to make voluntary self-disclosures to the DOJ in connection with…
- Dec 09, 2019
- Publications
In a recent settlement agreement, OFAC faulted a U.S. aviation company for failing to monitor or otherwise verify the actual location of leased aircraft engines over the life of the leases.
Litigation partner Roberto Gonzalez, the co-chair of Paul, Weiss’s Economic Sanctions and AML practice group, will speak on a panel at the American Conference Institute’s 10th NY Forum on Economic Sanctions.
- Nov 21, 2019
- Publications
On November 8, 2019, a Connecticut jury found Lawrence Hoskins, a British national and former executive of the French power and rail transportation company, Alstom S.A., guilty of participating in a scheme to bribe Indonesian…
- Oct 21, 2019
- Publications
Litigation partner Roberto Gonzalez and counsel Rachel Fiorill served as contributing editors and authored two chapters for the inaugural edition of The International Comparative Legal Guide (ICLG) to: Sanctions 2020, published by the …
- Oct 15, 2019
- Publications
The CFTC, the SEC and FinCen recently issued a joint statement reminding those engaged in activities involving digital assets of their anti-money laundering and counter-terrorist funding obligations under the Bank Secrecy Act
Litigation partner Roberto Gonzalez will speak on a panel at the Hispanic National Bar Association’s 2019 convention in New York.
- Sep 19, 2019
- Publications
On September 17, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $4,000,000 settlement agreement with the British Arab Commercial Bank plc (“BACB”), a commercial bank located in the…
- Aug 30, 2019
- Publications
On August 28, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced the launch of a new Global Investigations Division (“GID”), which will be responsible for implementing “targeted investigation…
- Aug 26, 2019
- Publications
On August 23, 2019, President Trump tweeted that “American companies are hereby ordered to immediately start looking for an alternative to China, including bringing. . .your companies [home] and making products in the USA.” In further …
- Aug 12, 2019
- Publications
On July 30, 2019, the U.S. Court of Appeals for the District of Columbia affirmed civil contempt orders by the D.C. District Court against three Chinese banks for their failure to produce documents in response to U.S. government…
- Jul 18, 2019
- Publications
Robust FCPA enforcement activity continued in the first half of 2019. The DOJ and the SEC—resolving four and five corporate enforcement actions, respectively—assessed a combined total of $1.5 billion in corporate penalties, of which…
On June 25, Paul, Weiss co-hosted an event with the China General Chamber of Commerce USA (CGCC), “Detecting and Reporting Suspicious Transactions and Preventing Sanctions Violations.”
- May 29, 2019
- Publications
On May 22, 2019, the New York State Department of Financial Services (“DFS”) announced the creation of a new Cybersecurity Division, which it described as the “first of its kind at a banking or insurance regulator.”
- May 14, 2019
- Publications
On May 2, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued guidance entitled “A Framework for OFAC Compliance Commitments” (the “Framework”), that strongly encourages companies to “develop,…
Litigation counsel Justin Lerer participated in a panel discussion on the “Shifting Tides in Anti-Money Laundering Enforcement and Regulation.”
- May 03, 2019
- Publications
On April 29, 2019, Linda Lacewell, the Acting Superintendent of the New York State Department of Financial Services (“DFS”), announced the combination of DFS’s previously separate Enforcement Division and Financial Frauds and Consumer …
- May 01, 2019
- Publications
On April 15, 2019, UniCredit Bank AG (“UCB AG”), headquartered in Munich, Germany, UniCredit Bank Austria AG (“Bank Austria”), headquartered in Vienna, Austria, and their corporate parent, UniCredit S.p.A., an Italian global banking…
Litigation counsel Karen King will speak on a panel at Consilio’s 3rd Annual Asia-Pacific New York City conference, “Caught in the Crossfire: Navigating Regulatory, Transactional and Litigation Risks in Light of Current U.S.-China…
Litigation partner Jessica Carey will deliver the keynote address at Gleiss Lutz’s annual Compliance & Investigations conference.
- Apr 01, 2019
- Publications
On March 27, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $1,869,144 settlement agreement with Connecticut-based Stanley Black & Decker, Inc. (“Stanley Black & Decker”), a…
- Feb 11, 2019
- Publications
On February 7, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $13,381 settlement agreement with Virginia-based Kollmorgen Corporation (“Kollmorgen”), a technology and manufacturing…
- Feb 05, 2019
- Publications
This memo surveys economic sanctions and AML developments and trends in 2018 and provides an outlook for the year ahead. We also provide some thoughts concerning compliance and risk mitigation in this challenging environment.
- Feb 04, 2019
- Publications
On January 31, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced a $996,080 settlement agreement with California-based e.l.f. Cosmetics, Inc. (“ELF”), to settle its potential civil liability for …
Litigation partner Chris Frey will participate in the “2019 Anti-Money Laundering Conference: Accelerating Implementation of a Risk Based Approach in Preparation for the Fourth FATF Mutual Evaluation of Japan,” sponsored by GoodWay,…
- Jan 17, 2019
- Publications
In this memo, we offer reflections on the year’s most significant developments in anti-corruption and FCPA enforcement and policy.
- Jan 07, 2019
- Publications
On December 11, 2018, the Securities and Exchange Commission (SEC) obtained a victory in its enforcement action against Alpine Securities Corporation, a broker that cleared transactions for microcap securities that were allegedly used …
- Nov 29, 2018
- Publications
On November 27, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced a nearly $90,000 settlement agreement with Virginia-based Cobham Holdings, Inc. (“Cobham”), a global provider of technology and…
- Oct 26, 2018
- Publications
On October 10, 2018, the Treasury Department announced that the interagency Committee on Foreign Investment in the United States (“CFIUS”) had used its new authority under the Foreign Investment Risk Review Modernization Act of 2018…
- Oct 10, 2018
- Publications
Firm chairman Brad Karp was featured in a Q&A in the latest issue of LEADERS magazine.
- Sep 15, 2018
- Publications
Ten years after the collapse of Lehman Brothers, market participants and other global companies operate in a markedly changed regulatory enforcement and compliance landscape. This memorandum discusses the legal and business…
- May 09, 2018
- Publications
On May 8, President Trump announced the unilateral withdrawal of the United States from the Iran nuclear deal, the Joint Comprehensive Plan of Action.
- Apr 13, 2018
- Publications
The first quarter of 2018 saw a flurry of declinations of FCPA prosecutions by the DOJ and the SEC, and only one FCPA corporate enforcement resolution by the DOJ and two resolutions by the SEC.
- Apr 10, 2018
- Publications
On April 6, 2018, the Trump administration imposed new sanctions on 7 Russian oligarchs, 12 companies they own or control, 17 Russian government officials, and a state-owned Russian weapons trading company and its subsidiary, a…
Litigation partner Roberto Gonzalez and counsel Rachel Fiorill will speak on panels at ACI’s 11th Annual Advanced Forum on Economic Sanctions Enforcement and Compliance.
In this video, litigation partners Mike Gertzman, Jessica Carey and Roberto Gonzalez and counsel Rachel Fiorill offer guidance for bolstering compliance as they discuss recent developments in sanctions and AML policy and enforcement.
Litigation partner Roberto Gonzalez will speak on a panel at the American Investment Council’s (AIC) Chief Compliance Officers Working Group Meeting.
- Feb 21, 2018
- Publications
A week after the announcement of a guilty plea and penalty related to Rabobank N.A.’s anti-money laundering violations, the DOJ announced on February 15 that it had entered into a deferred prosecution agreement with U.S. Bancorp,…
- Feb 21, 2018
- Publications
Since the financial crisis—and more recently in the wake of the Wells Fargo sales practices scandal and the benchmark manipulation enforcement actions—bank regulators in the United States and around the world have become increasingly…
- Feb 13, 2018
- Publications
The DOJ and the Office of the Comptroller of the Currency recently imposed a $368 million penalty on the U.S. subsidiary of Dutch-based Rabobank. The bank also pleaded guilty to conspiracy to obstruct regulatory oversight of its Bank …
- Feb 12, 2018
- Publications
On February 2, 2018, the Federal Reserve Board issued an unprecedented enforcement action against Wells Fargo & Company, prohibiting its asset growth until improvements in board oversight and firmwide risk management systems are…
- Feb 12, 2018
- Publications
On February 9, 2018, the United States Court of Appeals for the Second Circuit handed down a decision recognizing important limitations on the scope of the Antiterrorism Act (“ATA”).
- Feb 05, 2018
- Publications
On January 29, 2018, the Treasury Department submitted to Congress a report pursuant to Section 241 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”).
- Jan 23, 2018
- Publications
Economic sanctions and anti-money laundering remain top U.S. regulatory priorities, with federal and state agencies imposing over $2.5 billion in penalties in 2017.
- Jan 19, 2018
- Publications
Despite significant FCPA enforcement activity in 2017, the Trump administration’s approach to enforcement remains elusive and not readily characterized. While actions against individuals were at the highest level in recent years,…
- Jan 05, 2018
- Publications
The New York Department of Financial Services recently announced a consent order and imposed an $11 million penalty against a major Korean bank, NongHyup Bank, and its New York branch for repeatedly failing to maintain an adequate…
International trade counsel Richard Elliott will speak on a panel at the American Conference Institute’s (ACI) 4th National Forum on The Committee on Foreign Investment in the United States (CFIUS) & Team Telecom.
- Dec 20, 2017
- Publications
In light of the recent changes and increasing complexity in Russia/Ukraine-related sanctions, this memorandum provides an overview of the sanctions program as it exists today, focusing on both primary sanctions restrictions and…
On December 12, Roberto Gonzalez and Karen King will be guest speakers at the 2017 Chinese Financial Institutions’ Anti-Money Laundering and Sanctions Compliance Forum, sponsored by Ernst & Young and the China General Chamber of…
Recent months have witnessed important developments in the U.S. sanctions landscape, including new legislation, executive actions, and an uptick in enforcement by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC).
- Oct 13, 2017
- Publications
President Trump announced that he will not certify Iran’s compliance with the Joint Comprehensive Plan of Action, the multi-lateral commitment under which the United States, European Union, and five other countries agreed to lift…
- Sep 26, 2017
- Publications
On September 21, President Trump signed an executive order authorizing the Treasury Department to impose secondary sanctions against individuals and entities, including non-U.S. financial institutions, for conducting or facilitating…
- Aug 30, 2017
- Publications
The New York State Department of Financial Services (DFS) recently announced that it seeks to impose a nearly $630 million civil penalty against a non-U.S. bank and its New York branch for alleged persistent anti-money laundering and …
- Aug 03, 2017
- Publications
President Trump recently signed into law H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act.” The law significantly expands U.S. sanctions targeting Russia and restricts President Trump’s ability to lift them…
- Jul 28, 2017
- Publications
On July 27, 2017, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $12 million settlement with two Singapore-based companies over their use of U.S. dollar payments in connection with providing…
- Jul 18, 2017
- Publications
For the second time in two years, a federal appeals court has rejected a district court’s attempt to scrutinize a deferred prosecution agreement. The July 12 decision in U.S. v. HSBC Bank resolves, at least in the Second Circuit, the…
- Feb 22, 2017
- Publications
Economic sanctions, anti-money laundering and cybersecurity remain at the forefront of U.S. regulatory priorities. In this memorandum, we survey major developments and trends in these areas in 2016 and early 2017 and provide an…
- Sep 01, 2016
- Publications
On August 30, 2016, the U.S. Department of the Treasury, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of…
- Jul 01, 2016
- Publications
Following Maria Vullo's confirmation as Superintendent earlier this month, the New York Department of Financial Services ("DFS") yesterday finalized its closely watched proposed regulation on anti-money laundering (AML) monitoring and …
- May 10, 2016
- Publications
On May 6, 2016, the U.S. Treasury Department's Financial Crimes Enforcement Network ("FinCEN") released a final rule codifying new and existing customer due diligence ("CDD") requirements under the Bank Secrecy Act ("BSA") for covered …
- Feb 22, 2016
- Publications
Litigation partners Roberto Gonzalez and Jessica Carey co-authored an article in the February 22 issue of The National Law Journal.
- Feb 02, 2016
- Publications
The U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN) issued Geographic Targeting Orders ("GTO") imposing temporary reporting requirements on title insurers with respect to "all-cash" purchases of high-end…
- Jan 20, 2016
- Publications
On January 16, 2016, international inspectors verified that Iran had complied with the initial nuclear requirements of the Joint Comprehensive Plan of Action (the "JCPOA"), and the Secretary of State confirmed that verification.
- Sep 24, 2015
- Publications
The U.S. Department of the Treasury, Financial Crimes Enforcement Network ("FinCEN") proposed rules on August 25, 2015 that would broaden the application of the Bank Secrecy Act's ("BSA") suspicious activity reporting and anti-money…
- Jul 17, 2015
- Publications
The Treasury Department recently issued two companion reports, the National Money Laundering Risk Assessment and the National Terrorist Financing Risk Assessment, that address anti-money laundering and terrorist financing regulations…
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