Events & Publications
- 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. These areas remained a high priority last year, with the Trump administration making major changes in U.S.…
- 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 elect 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…
- 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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