FSR and Corporate Crime Notes

Updated DOJ Guidance Steers Effective Compliance and Remediation Programmes

OFAC Emphasizes Importance of Risk-Based Sanctions Compliance Programs for US and International Companies

Authors: John O'Donnell, Jonathan Cross, Geng Li, Christopher Milazzo, Susannah Cogman and Daniel Hudson Further emphasizing its expectation that all …

No More "Significant Reduction Waivers" – The Trump Administration Further Strengthens Sanctions against Iran

On April 22, 2019, the White House announced that the Trump administration will not issue further "significant reduction waivers" exempting specified …

High Court refuses permission for collateral use of disclosed documents and witness statements to respond to US grand jury subpoena

In a decision illustrating the court’s strict approach to the rule prohibiting the use of disclosed documents and witness statements for a collateral …

Corporate Crime Update - Winter 2019

Anti-money laundering regulatory round-up

Author: Susannah Cogman Late 2018 and early 2019 saw a flurry of regulatory developments and proposals relating to anti-money laundering. We have …

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 …

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 autumn update 2018

Welcome to the autumn 2018 edition of our corporate crime update - our round up of developments in relation to corruption, money …

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 …

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, …

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 …