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Newcomb, Danforth

Danforth Newcomb

Of Counsel
  • Sanctions Round Up: Fourth Quarter 2016 and President Donald J. Trump

    31 Jan 2017

    On November 8, 2016, Donald John Trump was elected the 45th President of the United States. Following fiery criticism of the Obama Administration’s sanctions policies, including the Iran deal, the lifting of substantial parts of the Cuban sanctions program, and the imposition of sanctions on Russia, it is likely that the new President will usher in a new era of US policy as it relates to Russian, Iran, and Cuban sanctions, although the nature, scope, and timing of such changes, not to mention Congressional views on certain of them, is still unknown.

  • Jay Clayton Nomination as SEC Chair and its Impact on the Commission’s FCPA Enforcement Priorities

    5 Jan 2017

    On January 4, 2017, President-elect Trump announced that he intended to nominate Jay Clayton, a Mergers & Acquisitions partner at Sullivan & Cromwell LLP, to succeed Mary Jo White as Chair of the SEC.

  • Shearman & Sterling’s Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA)/FCPA Digest

    3 Jan 2017
    Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best practices in FCPA and global anti-corruption compliance programs.
  • Iran Sanctions: OFAC Provides—at Least for Now—Assurances of a Wind-Down Period in Case of Snap-Back

    16 Dec 2016

    On December 15, 2016, the Office of Foreign Assets Control revised its Frequently Asked Questions guidance that concerns the re-imposition of sanctions in the event of a sanctions snapback under the Joint Comprehensive Plan of Action (“JCPOA”). The amended FAQs, which can be found below, convey OFAC’s general view that should the US re-impose certain sanctions pursuant to a JCPOA snapback, the US government would provide a 180-day wind-down period for payments related to contracts entered into and executed during the JCPOA period. In addition, OFAC also issued License J-1, which authorizes the temporary re-export of certain aircraft that are involved in code-sharing arrangements.

  • Ramifications of US Election for International Sanctions

    9 Nov 2016

    Yesterday’s election has significant implications for international sanctions, particularly with respect to Iran, Cuba, and Russia. Although we do not want to be unduly alarmist, President-elect Trump’s statements on the campaign trail, should they be carried through to policy in his Administration, certainly suggest a U-turn in US policy. With respect to Iran and Cuba, the possibility of such a change in direction will need to be taken into account by persons and companies who have begun to enter into commercial arrangements with those countries in the expectation that the recent easing of sanctions would continue. With respect to Russia, we do not advise that any company make any assumptions as to the shape of future sanctions. Although any potential shifts in US policy would not officially occur before President-elect Trump takes office, it is likely that some of the potential changes will be telegraphed before the Inauguration in January 2017.

  • Sanctions Roundup: Third Quarter 2016 and Executive Order on Burmese Sanctions

    2 Nov 2016

    OFAC, acting under the direction of President Obama’s Executive Orders, has lifted the economic and financial sanctions against Burma and Côte D’Ivoire. The revisions open these countries, and their financial markets, to significant Western investment. Iran continues to allege that Western financial institutions have refused to enter its markets despite the Joint Comprehensive Plan of Action. Additionally, the European Council and OFAC continue to impose and expand sanctions against Russia for its annexation of Crimea and disruptive activities in eastern Ukraine.

  • NYS Department of Financial Services Outlines Requirements for Transaction Monitoring and Filtering Programs of NY State-Licensed Institutions

    20 Jul 2016
    On June 30, 2016, the New York State Department of Financial Services (“NYSDFS”) adopted a final regulation outlining the attributes of a risk-based transaction monitoring and filtering program that certain New York State-licensed institutions now will be required to maintain (the “Final Rule”). The Final Rule includes several notable departures from the proposal that was issued by the NYSDFS on December 1, 2015 (the “Proposed Rule”). The Final Rule, which is the first significant rulemaking to be finalized under the direction of the new Superintendent of Financial Services, Maria T. Vullo, is another example of the NYSDFS asserting its role in establishing standards for compliance by banks with anti-money laundering, terrorist financing and sanctions laws.
  • Shearman & Sterling's Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA) / FCPA Digest

    5 Jul 2016

    Shearman & Sterling’s bi-annual Trends & Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA and global anti-corruption compliance programs.

  • FinCEN Issues Final Beneficial Owner Identification Rules

    14 Jun 2016

    In May 2016, the U.S. Treasury Department’s Financial Crimes Enforcement Network issued final rules regarding beneficial owner identification obligations for legal entity customers (the “Rule”).

  • To Self-Report or Not to Self-Report, That Remains the Question After the Justice Department’s Latest Effort to Encourage Self-Reporting

    29 Apr 2016

    On April 5, 2016, the United States Department of Justice, Criminal Division, Fraud Section launched a one-year Pilot Program that invites companies to self-report potential violations of the Foreign Corrupt Practices Act (“FCPA”) to the FCPA Unit of the Justice Department in exchange for, among other things, up to a fifty percent reduction in criminal fines, declination and, where appropriate, settlements without a compliance monitor.

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Education

  • Columbia University School of Law, J.D., 1968
  • University of Vermont, B.A., 1965

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