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The importance of supply chain due diligence and the risks of modern slavery – OFAC settles North Korean sanctions case with fine
Authors: Kyle Wombolt, Jeremy Birch, Antony Crockett and Emily Purvis. A recent enforcement action by the US Department of the Treasury’s Office of …
HERBERT SMITH FREEHILLS’ 2019 GUIDE TO CORPORATE INVESTIGATIONS IN CHINA
Authors: Kyle Wombolt and Anita Phillips Kyle Wombolt, global head of corporate crime and investigations, and Anita Phillips, professional support …
OFAC Imposes Blocking Sanctions on PdVSA
Authors: Susannah Cogman, Partner, London; Daniel Hudson, Partner, London; Jonathan Cross, Counsel, New York; Geng Li, Associate, New York; and …
Corporate Crime update - December 2018
Welcome to the December 2018 edition of our corporate crime update - our round up of developments in relation to corruption, money laundering, …
Corporate Crime autumn update 2018
Welcome to the autumn 2018 edition of our corporate crime update - our round up of developments in relation to corruption, money …
Hong Kong SFC commences thematic review of risk governance and oversight frameworks, including assessment of risk management MICs
Last Friday, the SFC announced (via a circular) that it had commenced a thematic review of selected licensed corporations (LCs) to assess their risk …
Second Wave of United States Sanctions Against Iran Re-Imposed
Following President Trump’s decision on May 8, 2018 to withdraw the United States from the Joint Comprehensive Plan of Action (“JCPOA”), the US …
High Court considers extraterritorial application of compulsory powers
In the case of R (On The Application Of KBR Inc) v The Director of the Serious Fraud Office [2018] EWHC 2368 (Admin) ("KBR"), the High …
SANCTIONS CLAUSES IN A CHANGING SANCTIONS REGIME
How far can a sanctions clause protect a party from having to perform their contractual obligations - and in the case of Iran-related sanctions concerns, …
OFSI publishes Annual Review
On 5 October 2018, HM Treasury's Office of Financial Sanctions Implementation (OFSI) published its Annual Review for the 2017-18 financial year. This is …
FinCEN Issues Advisory Regarding Detection of Illicit Transactions Related to Iran
On October 11, 2018, the Financial Crimes Enforcement Network ("FinCEN") issued official guidance entitled "Advisory on the Iranian Regime's Illicit and …
FATCA Update: First-ever conviction signals increased enforcement risk
The former CEO of Saint Vincent-based Loyal Bank pleaded guilty and was convicted on 11 September of conspiring to defraud the US by failing to comply …
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