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Anti-Corruption & Foreign Corrupt Practices Act (FCPA)

  • SEC Settlement with Layne Christensen Raises New Questions on the Government’s Understanding of the Business Nexus Element of the FCPA

    4 Nov 2014
    Last week the SEC settled charges against Layne Christensen for various violations of the FCPA. While a relatively unremarkable case at first glance, the SEC’s charges against Layne Christensen reflect a troubling approach by enforcement agencies to disregard the “business nexus element” of the FCPA’s anti-bribery provisions. These recent practices appear to contradict the Fifth Circuit’s opinion in United States v. Kay and create greater uncertainty as to the scope of the statute.
  • Sanctions Round-Up: Third Quarter 2014

    20 Oct 2014
    The third quarter of 2014 was marked by the issuance and then significant expansion of U.S. and E.U. sanctions targeting specific sectors of the Russian economy. These sectoral sanctions complement ongoing efforts by both jurisdictions to identify and designate persons contributing to the ongoing instability in eastern Ukraine.
  • Russia Sanctions: Impact on Financial Institutions in the US, EU and Japan

    25 Aug 2014

    New sanctions targeting Russia have been implemented in the US, EU and Japan. Although the consequences of breaching the sanctions are severe, navigating the rules is not straightforward. Transactions and business lines will need to be reconsidered in light of the complex rules to which they may be subject. This client publication highlights the key issues and differences in the US, EU and Japanese rules that companies should understand.

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

    21 Jul 2014
    Shearman & Sterling’s bi-annual Trends and 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. While the first half of 2014 brought relatively fewer corporate enforcement actions, higher than average penalties, increased individual prosecutions, and several developments in ongoing cases have provided insights into evolving enforcement trends.
  • Sanctions Round-Up: Second Quarter 2014

    9 Jul 2014

    The headline for the second quarter is, of course, the United States’ enforcement action against Bank BNP Paribas and its breathtaking penalty of $8.9 billion, tied to the allegedly intentional evasion of the US sanctions programs for Sudan and, to a lesser extent, Iran and Cuba. This settlement capped off a series of enforcement actions by US authorities against a variety of actors stemming from violations of all sizes.

  • So You Want to See Messi, Neymar, Ronaldo, and Xavi: Brazil Issues Directive Barring Government Officials From Receiving World Cup Tickets

    2 Jun 2014
    Earlier today, the Comptroller’s Office in Brazil, Controladoria-Geral da União (“CGU”), issued a sweeping directive barring government officials from accepting offers to attend or participate in the upcoming 2014 FIFA World Cup events set to begin in Brazil on June 12, 2014.
  • OFAC Settles Civil Enforcement Action with Dutch Company for Alleged Violations of US Trade Embargo on Cuba

    25 Apr 2014
    The US Treasury’s Office of Foreign Assets Control (OFAC) and Carlson Wagonlit Travel (i.e., CWT B.V.), a Netherlands-based company, have agreed to settle violations of the Cuban Assets Control Regulations (CACRs) dating back to as early as August 2006.
  • Sanctions Round-Up: First Quarter 2014

    3 Apr 2014
    The first quarter of 2014 opened with a continued focus on Iran, as US authorities somewhat contradictorily took steps both to ease certain Iranian sanctions, as agreed under the Joint Plan of Action, and to target a number of additional Iranian persons under existing sanctions.
  • A Potential Fork in the Road: US and EU Sanctions Relating to the Ukrainian Crisis

    1 Apr 2014

    Both the United States and the European Union have issued calibrated Ukraine-related sanctions as a direct response to the recent political upheaval in Ukraine.

  • Sanctions Round-Up: Fourth Quarter 2013

    7 Jan 2014
    As 2013 drew to a close, a potentially groundbreaking agreement was reached with Iran regarding its nuclear program, leading to much speculation about how certain sanctions might be suspended, and under what conditions.
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