ProfessionalsChristopher D. Frey

Christopher D. Frey
Partner
Tel: +81-3-3597-6309
Fax: +81-3-6369-4937
emailcfrey@paulweiss.com
Fukoku Seimei Building 2F, 2-2, Uchisaiwaicho 2-chome
Chiyoda-ku,
Tokyo
100-0011, Japan
Fax: +81-3-6369-4937
Christopher D. Frey, a former federal prosecutor and a partner in the Litigation Department, focuses his practice on white-collar and regulatory defense, government and internal investigations, and high-stakes litigation.
EXPERIENCE
Chris regularly advises major Japanese and other global financial institutions and companies in their most sensitive matters, and has significant experience in the Foreign Corrupt Practices Act (FCPA), anti-money laundering, and economic sanctions areas. Chris also routinely provides strategic counseling on compliance issues and crisis management.
Chris’s current and recent representations include:
- A significant Japanese financial institution in U.S. regulatory proceedings;
- A Japanese company in connection with an investigation conducted by a multilateral development bank of potential corruption issues;
- Japanese companies in Foreign Corrupt Practices Act investigations;
- A major Japanese conglomerate and its U.S. subsidiary in a U.S. regulatory investigation;
- Former Nissan Motor Co. Chairman Carlos Ghosn in high profile criminal charges and civil claims in the United States and Japan, including a civil settlement with the U.S. Securities and Exchange Commission;
- An Asia-based manufacturing company in a sanctions, money laundering, and bank fraud investigation by the U.S. Department of Justice; and
- Several non-U.S. financial institutions in Bank Secrecy Act/anti-money laundering matters, including advising on remedial measures and compliance program enhancements.
Chris previously served for over six and a half years as an Assistant U.S. Attorney in the Criminal Division of the U.S. Attorney’s Office for the Southern District of New York. There, he was a member of the Securities & Commodities Fraud Task Force and the Complex Frauds and Cybercrime Unit. Chris investigated and prosecuted a wide array of complex white-collar matters, including FCPA violations, insider trading, accounting fraud, market manipulation, investment advisor fraud, money laundering, intellectual property and cybercrimes, and criminal tax offenses. During his tenure as a prosecutor, Chris was the lead trial lawyer in numerous jury trials, and he has substantial appellate experience, having briefed and/or argued over a dozen appeals before the U.S. Court of Appeals for the Second Circuit. Chris is a recipient of the U.S. Department of Justice’s John Marshall Award for Outstanding Legal Achievement.
From 2014 to 2015, Chris served as Associate Counsel in the Office of the White House Counsel under President Barack Obama. In that capacity, Chris helped develop and execute the White House’s response to various Congressional investigations, and provided legal and strategic advice to White House staff and Executive Branch officials on compliance, oversight, and risk management issues.
Chris has previously served on both the New York City Bar Association’s Criminal Advocacy Committee and its Judiciary Committee, which reviews and evaluates all judicial candidates for the federal and state courts in New York City.
Chris served as a notes editor for the Stanford Law Review. He is registered as a gaikokuho jimu bengoshi in Japan.
Related Resources
New Guidance Clarifies OFAC’s Broad Interpretation of Recent Sanctions Against Communist Chinese Military Companies
- Jan 04, 2021
- Publications
New Guidance Clarifies OFAC’s Broad Interpretation of Recent Sanctions Against Communist Chinese Military Companies
OFAC recently published guidance clarifying the scope of the Trump Administration’s sanctions prohibiting U.S. persons from engaging in transactions involving publicly traded securities of any identified “Communist Chinese military…
FinCEN Proposes New Requirements for Reporting and Recordkeeping on Certain Transactions Involving Convertible Virtual Currency and Digital Asset Transactions
- Dec 29, 2020
- Publications
FinCEN Proposes New Requirements for Reporting and Recordkeeping on Certain Transactions Involving Convertible Virtual Currency and Digital Asset Transactions
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) recently proposed rulemaking that would extend existing Bank Secrecy Act reporting and recordkeeping requirements on financial institutions for certain…
United States Imposes Sanctions on Turkey under CAATSA Section 231 for Purchase of Russian Missile System
- Dec 21, 2020
- Publications
United States Imposes Sanctions on Turkey under CAATSA Section 231 for Purchase of Russian Missile System
The United States recently imposed sanctions on Turkey’s Presidency of Defense Industries under the Countering America’s Adversaries Through Sanctions Act (CAATSA), which mandates sanctions against non-U.S. persons who conduct…
FCPA Developments: Q3 2020
- Oct 16, 2020
- Publications
FCPA Developments: Q3 2020
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…
The OCC Issues Guidance Confirming that National Banks and Federal Savings Associations May Hold Reserves for Certain Stablecoins
- Sep 29, 2020
- Publications
The OCC Issues Guidance Confirming that National Banks and Federal Savings Associations May Hold Reserves for Certain Stablecoins
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.
Second Circuit Rejects Evasion-of-Secondary-Sanctions Theory; Upholds DOJ’s Use of Bank Fraud Statute in Sanctions Prosecution
- Aug 31, 2020
- Publications
Second Circuit Rejects Evasion-of-Secondary-Sanctions Theory; Upholds DOJ’s Use of Bank Fraud Statute in Sanctions Prosecution
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…
Federal Agencies Provide Guidance on BSA/AML Enforcement and Due Diligence Requirements
- Aug 24, 2020
- Publications
Federal Agencies Provide Guidance on BSA/AML Enforcement and Due Diligence Requirements
Federal banking agencies, along with FinCEN, recently issued new guidance on BSA/AML enforcement and customer due diligence obligations.
GDPR Issues In International Arbitration
- Aug 10, 2020
- Publications
GDPR Issues In International Arbitration
Given the broad reach, complexity and comprehensiveness of the EU’s General Data Protection Regulations (GDPR), parties to international arbitrations need to be particularly mindful of data protection issues raised throughout…
DOJ and OFAC Enforcement Actions Against Essentra FZE Signal New Sanctions Risks for Non-U.S. Companies Utilizing the U.S. Financial System
- Jul 23, 2020
- Publications
DOJ and OFAC Enforcement Actions Against Essentra FZE Signal New Sanctions Risks for Non-U.S. Companies Utilizing the U.S. Financial System
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…
President Trump Signs the Hong Kong Autonomy Act into Law and Issues an Implementing Executive Order
- Jul 21, 2020
- Publications
President Trump Signs the Hong Kong Autonomy Act into Law and Issues an Implementing Executive Order
President Trump recently signed the Hong Kong Autonomy Act (HKAA) into law and issued an executive order implementing the HKAA.
UK FCA Imposes £37 Million Penalty on Commerzbank for AML Failures
- Jun 22, 2020
- Publications
UK FCA Imposes £37 Million Penalty on Commerzbank for AML Failures
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.
DOJ 2020 Guidance for Evaluating Corporate Compliance Incorporates Feedback From Business and Compliance Communities
- Jun 08, 2020
- Publications
DOJ 2020 Guidance for Evaluating Corporate Compliance Incorporates Feedback From Business and Compliance Communities
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…
Supreme Court: New York Convention Doesn’t Bar Non-Signatories to an International Arbitration Agreement from Seeking to Compel Arbitration
- Jun 08, 2020
- Publications
Supreme Court: New York Convention Doesn’t Bar Non-Signatories to an International Arbitration Agreement from Seeking to Compel Arbitration
In GE Energy Power Conversion France SAS v. Outokumpu Stainless USA, LLC, the Supreme Court held that the Convention on the Recognition and Enforcement of Foreign Arbitral Awards does not preclude a nonsignatory to an international…
U.S. Government Issues Updated Sanctions Compliance Guidance for the Maritime Industry
- May 19, 2020
- Publications
U.S. Government Issues Updated Sanctions Compliance Guidance for the Maritime Industry
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…
OFAC Enforcement Action against BIOMIN America, Inc. Highlights the Consequences of Failing to Seek and Implement Appropriate Compliance Advice
- May 14, 2020
- Publications
OFAC Enforcement Action against BIOMIN America, Inc. Highlights the Consequences of Failing to Seek and Implement Appropriate Compliance Advice
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,…
Paul, Weiss Secures Release of Wrongfully Convicted Pro Bono Client
- May 04, 2020
- Client News
Paul, Weiss Secures Release of Wrongfully Convicted Pro Bono Client
U.S. District Judge Leon Jordan of the Eastern District of Tennessee ordered the release of Ronnie Cooper, a federal inmate convicted in 2010 based on his alleged participation in a drug trafficking ring and sentenced to 30 years in…
Bank Hapoalim Enters into Criminal and Civil Resolutions for Its Participation in Separate Tax Evasion and Money Laundering Conspiracies, and Agrees to Pay Nearly $1 Billion in Penalties
- May 05, 2020
- Publications
Bank Hapoalim Enters into Criminal and Civil Resolutions for Its Participation in Separate Tax Evasion and Money Laundering Conspiracies, and Agrees to Pay Nearly $1 Billion in Penalties
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.
Eni S.p.A. Agrees to Resolve FCPA Charges As Controlling Minority Shareholder of Saipem S.p.A.
- Apr 30, 2020
- Publications
Eni S.p.A. Agrees to Resolve FCPA Charges As Controlling Minority Shareholder of Saipem S.p.A.
On April 17, 2020, the U.S. Securities and Exchange Commission (“SEC”) announced that it had resolved charges against Eni S.p.A., an Italian headquartered multinational oil and gas company, for violations of the recordkeeping and…
Industrial Bank of Korea Reaches $86 Million AML Resolution with DOJ, NY Attorney General, and NY DFS
- Apr 24, 2020
- Publications
Industrial Bank of Korea Reaches $86 Million AML Resolution with DOJ, NY Attorney General, and NY DFS
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 …
OFAC Cites the Use of U.S.-Origin Software and U.S. Network Infrastructure in Reaching a Nearly $8 Million Settlement with a Swiss Commercial Aviation Services Company
- Mar 16, 2020
- Publications
OFAC Cites the Use of U.S.-Origin Software and U.S. Network Infrastructure in Reaching a Nearly $8 Million Settlement with a Swiss Commercial Aviation Services Company
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.
2020 FCPA Developments: A Judge Overturns Hoskins’s FCPA Guilty Verdict Under an Agency Theory; Cardinal Health Resolves FCPA Investigation with the SEC
- Mar 13, 2020
- Publications
2020 FCPA Developments: A Judge Overturns Hoskins’s FCPA Guilty Verdict Under an Agency Theory; Cardinal Health Resolves FCPA Investigation with the SEC
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…
FinCEN Imposes Its First Penalty on a Bank Compliance Officer for $450,000 for Failing to Prevent AML Violations
- Mar 09, 2020
- Publications
FinCEN Imposes Its First Penalty on a Bank Compliance Officer for $450,000 for Failing to Prevent AML Violations
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.…
Ring LLC Faces a Proposed Class Action Alleging Camera Doorbells Should Incorporate Enhanced Cybersecurity Features
- Feb 03, 2020
- Publications
Ring LLC Faces a Proposed Class Action Alleging Camera Doorbells Should Incorporate Enhanced Cybersecurity Features
On December 26, 2019, Amazon and Ring LLC were named as defendants in a putative class action filed in the U.S. District Court for the Central District of California by plaintiffs alleging claims of over $5 million.
Economic Sanctions and Anti-Money Laundering Developments: 2019 Year in Review
- Jan 31, 2020
- Publications
Economic Sanctions and Anti-Money Laundering Developments: 2019 Year in Review
This memorandum surveys economic sanctions and anti-money laundering (“AML”) developments and trends in 2019 and provides an outlook for the year ahead.
FCPA Enforcement and Anti-Corruption Developments - 2019 Year in Review
- Jan 24, 2020
- Publications
FCPA Enforcement and Anti-Corruption Developments - 2019 Year in Review
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.
DOJ Announces Revised Export Control and Sanctions Enforcement Policy for Companies, Including Financial Institutions
- Dec 19, 2019
- Publications
DOJ Announces Revised Export Control and Sanctions Enforcement Policy for Companies, Including Financial Institutions
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…
OFAC Enforcement Action against U.S. Aviation Company Shows the Importance of Ongoing Monitoring over the Course of a Contractual Relationship
- Dec 09, 2019
- Publications
OFAC Enforcement Action against U.S. Aviation Company Shows the Importance of Ongoing Monitoring over the Course of a Contractual Relationship
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.
Samsung Heavy Industries Agrees to Pay $75 Million to DOJ and Brazilian Authorities to Resolve FCPA Charges
- Dec 05, 2019
- Publications
Samsung Heavy Industries Agrees to Pay $75 Million to DOJ and Brazilian Authorities to Resolve FCPA Charges
On November 22, 2019, the Department of Justice announced that it had reached a resolution with Samsung Heavy Industries Company Ltd. (“SHI”) relating to a scheme to pay millions of dollars in bribes to officials of Petróleo…
Jury Convicts Foreign National of FCPA Violations under Agency Theory
- Nov 21, 2019
- Publications
Jury Convicts Foreign National of FCPA Violations under Agency Theory
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…
VinDAX Is the Seventh Cryptocurrency Exchange Hacked This Year: What Should Investors Be Considering?
- Nov 21, 2019
- Publications
VinDAX Is the Seventh Cryptocurrency Exchange Hacked This Year: What Should Investors Be Considering?
On November 5, 2019, Vietnam-based cryptocurrency exchange VinDAX was hacked, losing half a million U.S. dollars’ worth of funds spread across 23 different cryptocurrencies.[1]
Social Media Bot Company Devumi LLC Reaches $2.5 Million Settlement with FTC for Sale of Misleading Social Media “Influence Indicators”
- Oct 28, 2019
- Publications
Social Media Bot Company Devumi LLC Reaches $2.5 Million Settlement with FTC for Sale of Misleading Social Media “Influence Indicators”
On October 21, 2019, the Federal Trade Commission (“FTC”) settled its first-ever complaint against a company for selling fake indicators of social media influence such as phony likes, follows, views, and subscribers to users on…
Recent Cyber Attacks Target Asset Management Firms
- Oct 28, 2019
- Publications
Recent Cyber Attacks Target Asset Management Firms
A recent flurry of cyber attacks on asset managers should remind asset management firms and other financial institutions that they are attractive targets for cyber-exploitation and need to remain vigilant and institute appropriate…
China’s State Grid to Acquire Chilean Power Company Chilquinta Energía
- Oct 14, 2019
- Client News
China’s State Grid to Acquire Chilean Power Company Chilquinta Energía
Paul Weiss is advising China-based utilities company State Grid International Development Limited in its $2.23 billion acquisition of Chilquinta Energía S.A. from Sempra Energy.
Federal Agencies Issue Joint Statement on AML/CFT Obligations, and IRS Updates Guidance, for Digital Assets
- Oct 15, 2019
- Publications
Federal Agencies Issue Joint Statement on AML/CFT Obligations, and IRS Updates Guidance, for Digital Assets
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
DOJ Announces Guidance for “Inability-to-Pay” Claims
- Oct 10, 2019
- Publications
DOJ Announces Guidance for “Inability-to-Pay” Claims
On October 8, 2019, the Criminal Division of the U.S. Department of Justice released guidance on how federal prosecutors should evaluate claims that corporations are unable to pay a proposed fine or monetary penalty.
SEC Concludes the 2018-19 Fiscal Year with Four FCPA Enforcement Actions
- Oct 08, 2019
- Publications
SEC Concludes the 2018-19 Fiscal Year with Four FCPA Enforcement Actions
The SEC closed out its 2018-19 fiscal year by resolving four FCPA enforcement actions and assessing over $25 million in combined penalties, bringing the total number of SEC resolutions in 2019 to twelve.
Paul, Weiss Strikes SEC Settlement for Former Nissan Chair Carlos Ghosn
- Sep 23, 2019
- Client News
Paul, Weiss Strikes SEC Settlement for Former Nissan Chair Carlos Ghosn
Paul, Weiss advised former Nissan Motor Co. Chairman Carlos Ghosn in his $1 million civil settlement with the U.S. Securities and Exchange Commission.
OFAC Reaches Settlement Agreement with U.K. Bank for Complex Payment Structures Used to Circumvent U.S. Sanctions
- Sep 19, 2019
- Publications
OFAC Reaches Settlement Agreement with U.K. Bank for Complex Payment Structures Used to Circumvent U.S. Sanctions
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…
FinCEN Announces Launch of New Global Investigations Division Focused on Exercising Section 311 and Geographic Targeting Order Authorities
- Aug 30, 2019
- Publications
FinCEN Announces Launch of New Global Investigations Division Focused on Exercising Section 311 and Geographic Targeting Order Authorities
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…
Does President Trump Have Authority to Force U.S. Companies to Leave China?
- Aug 26, 2019
- Publications
Does President Trump Have Authority to Force U.S. Companies to Leave China?
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 …
D.C. Circuit Upholds Decision Requiring Three Chinese Banks to Produce Documents Located in China to the U.S. Government
- Aug 12, 2019
- Publications
D.C. Circuit Upholds Decision Requiring Three Chinese Banks to Produce Documents Located in China to the U.S. Government
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…
FCPA Enforcement and Anti-Corruption Developments: 2019 Mid-Year Review
- Jul 18, 2019
- Publications
FCPA Enforcement and Anti-Corruption Developments: 2019 Mid-Year Review
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…
TechnipFMC Agrees to Pay $296 Million to DOJ and Brazilian Authorities to Resolve Criminal FCPA Charges; SEC Civil Charges Pending
- Jul 02, 2019
- Publications
TechnipFMC Agrees to Pay $296 Million to DOJ and Brazilian Authorities to Resolve Criminal FCPA Charges; SEC Civil Charges Pending
On June 25, 2019, the Department of Justice announced a resolution with Technip FMC PLC (“TFMC”), a London-headquartered, global provider of oil and gas technology and services that is listed on the New York Stock Exchange, for…
Walmart Pays $282 Million for Failing to Maintain a Sufficient Anti-Corruption Compliance Program
- Jun 25, 2019
- Publications
Walmart Pays $282 Million for Failing to Maintain a Sufficient Anti-Corruption Compliance Program
On June 20, 2019, the Department of Justice and the Securities and Exchange Commission announced long-awaited resolutions with Walmart, Inc. for violations of the books and records and internal accounting provisions of the Foreign…
OFAC Issues Guidance on Sanctions Compliance Programs and Flags “Root Causes” Underlying Prior Enforcement Actions
- May 14, 2019
- Publications
OFAC Issues Guidance on Sanctions Compliance Programs and Flags “Root Causes” Underlying Prior Enforcement Actions
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,…
SEC Fines Telefônica Brasil S.A. $4.125 Million Relating to World Cup Tickets Given to Government Officials
- May 13, 2019
- Publications
SEC Fines Telefônica Brasil S.A. $4.125 Million Relating to World Cup Tickets Given to Government Officials
On May 9, 2019, the SEC fined Telefônica Brasil S.A. a $4.125 million civil penalty to resolve allegations that the company‘s internal accounting controls failed to protect sufficiently against the risk that things of value, like…
DOJ Updated Guidance for Evaluating Corporate Compliance Programs Focuses on Effectiveness
- May 06, 2019
- Publications
DOJ Updated Guidance for Evaluating Corporate Compliance Programs Focuses on Effectiveness
On April 30, 2019, the Criminal Division of the U.S. Department of Justice released updated guidance on how prosecutors evaluate the effectiveness of corporate compliance programs.
New York DFS Creates New “Powerhouse” Division Combining the Enforcement Division and Financial Frauds and Consumer Protection Division
- May 03, 2019
- Publications
New York DFS Creates New “Powerhouse” Division Combining the Enforcement Division and Financial Frauds and Consumer Protection Division
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 …
UniCredit Group Banks Agree to Pay a Combined $1.3 Billion Penalty for Iranian and Other Sanctions Violations; One Bank Pleads Guilty
- May 01, 2019
- Publications
UniCredit Group Banks Agree to Pay a Combined $1.3 Billion Penalty for Iranian and Other Sanctions Violations; One Bank Pleads Guilty
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…
OFAC Takes Enforcement Action Against U.S. Parent Company for its Recently Acquired Chinese Subsidiary’s Iran Sanctions Violations
- Apr 01, 2019
- Publications
OFAC Takes Enforcement Action Against U.S. Parent Company for its Recently Acquired Chinese Subsidiary’s Iran Sanctions Violations
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…
DOJ, FBI, and CFTC Announce FCPA Policy Revisions and Initiatives
- Mar 15, 2019
- Publications
DOJ, FBI, and CFTC Announce FCPA Policy Revisions and Initiatives
The Department of Justice announced last week several revisions to its Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy, which includes relaxing prior guidance on how companies should deal with employees’ use of…
Mobile TeleSystems PJSC Reaches $850 Million Resolutions with DOJ and SEC Over FCPA Violations
- Mar 12, 2019
- Publications
Mobile TeleSystems PJSC Reaches $850 Million Resolutions with DOJ and SEC Over FCPA Violations
In the latest dramatic chapter of the long-running bribery saga that has pervaded the telecommunications sector in Uzbekistan, on March 6 and 7, 2019, the Department of Justice (“DOJ”) and the Securities and Exchange Commission…
Christopher D. Frey to Participate in Anti-Money Laundering Conference
- Feb 08, 2019
- Events
Christopher D. Frey to Participate in Anti-Money Laundering Conference
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,…
FCPA Enforcement and Anti-Corruption Developments: 2018 Year in Review
- Jan 17, 2019
- Publications
FCPA Enforcement and Anti-Corruption Developments: 2018 Year in Review
In this memo, we offer reflections on the year’s most significant developments in anti-corruption and FCPA enforcement and policy.
Paul, Weiss Announces Election of New Partners
- Dec 07, 2018
- Firm News
Paul, Weiss Announces Election of New Partners
Paul, Weiss is pleased to announce that the following attorneys have been elected to the partnership, effective January 1, 2019: Justin Anderson, Robert Britton, David Carmona, Harris Fischman, Christopher D. Frey, Matthew B.…
Behind Petrobras $1.8 Billion FCPA Settlement, An Interesting Accounting
- Oct 02, 2018
- Publications
Behind Petrobras $1.8 Billion FCPA Settlement, An Interesting Accounting
On September 27, 2018, the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) announced coordinated enforcement resolutions with Petróleo Brasileiro S.A. – Petrobras, the Brazilian state-owned…
Supreme Court Rules That Costs of Internal Investigation Are Not Recoverable As Restitution under the Mandatory Victims Restitution Act of 1996
- May 30, 2018
- Publications
Supreme Court Rules That Costs of Internal Investigation Are Not Recoverable As Restitution under the Mandatory Victims Restitution Act of 1996
On May 29, 2018, in Lagos v. United States, the Supreme Court unanimously held that the Mandatory Victims Restitution Act of 1996 (the “MVRA”)[1] does not require a criminal defendant to pay the costs and attorneys’ fees associated…
President Trump Withdraws the United States from the Iran Nuclear Deal
- May 09, 2018
- Publications
President Trump Withdraws the United States from the Iran Nuclear Deal
On May 8, President Trump announced the unilateral withdrawal of the United States from the Iran nuclear deal, the Joint Comprehensive Plan of Action.
Christopher Frey to Speak at Wall Street Journal’s Anti-Corruption Event
- Nov 10, 2016
- Events
Christopher Frey to Speak at Wall Street Journal’s Anti-Corruption Event
Litigation counsel Christopher Frey will participate in a panel discussion at an upcoming Wall Street Journal luncheon addressing anti-corruption enforcement developments and compliance.
Christopher Frey to Address FCPA Compliance at ALB Corporate Forum in Japan
- Sep 27, 2016
- Events
Christopher Frey to Address FCPA Compliance at ALB Corporate Forum in Japan
Litigation counsel Christopher Frey will participate in a panel discussion, titled "Ensuring FCPA Compliance in the APAC Region," at Asian Legal Business' upcoming Japan Corporate Compliance and Governance Forum.
OECD Criticizes Japan for Leniency in Combatting Foreign Bribery
- Jul 20, 2016
- Publications
OECD Criticizes Japan for Leniency in Combatting Foreign Bribery
On June 30, 2016, following a two-day high-level mission to Tokyo, Japan to meet with senior government officials and representatives, the Organization for Economic Cooperation and Development ("OECD") Working Group on Bribery in …
Client Alert: DOJ and SEC Pressure Test Accuracy of Self-Reporting and Cooperation in PTC FCPA Settlement
- Feb 29, 2016
- Publications
Client Alert: DOJ and SEC Pressure Test Accuracy of Self-Reporting and Cooperation in PTC FCPA Settlement
On February 16, 2016, the Securities and Exchange Commission and the Department of Justice announced settled parallel enforcement and criminal actions against Massachusetts-based technology company PTC, Inc. and its two…