6 Dec 2013
Shearman & Sterling Litigation partner Philip Urofsky
and of counsel Dan Newcomb
authored an article in the Journal of Investment Compliance
titled “FCPA Broker-Dealer Case Highlights Compliance Risks for Financial Institutions.”
5 Dec 2013
On November 23, 2013, Iran and the five permanent members of the United Nations Security Council (China, France, Russia, United Kingdom, United States) and Germany (P5+1) reached an incremental and interim Joint Plan of Action that proposes suspending certain sanctions targeting Iran.
8 Oct 2013
Following a flurry of activity at the end of the last quarter, U.S. authorities were almost silent on the sanctions front in the third quarter of 2013.
12 Jul 2013
The end of the second quarter was marked by a flurry of Iran related activity, with President Obama authorizing new sanctions targeting Iran and OFAC preparing for IFCA sanctions that came into effect on July 1.
5 Jun 2013
Much of the coverage of the recent Foreign Corrupt Practices Act case against Ralph Lauren Corp. (RLC) focused on the fact that both the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) awarded it a Non-Prosecution Agreement (NPA) due to its prompt voluntary disclosure and subsequent cooperation. The facts of the case, however, point to the steady entrenchment of a more ominous prosecution theory: an approach that appears to approximate strict criminal and civil liability of parent corporations for their subsidiaries’ corrupt acts.
30 May 2013
The US government has again expanded the scope of its Iranian extraterritorial sanctions program with the enactment of the Iran Freedom and Counter Proliferation Act of 2012 (the “IFCPA”).
13 May 2013
Last week saw a significant Foreign Corrupt Practices Act (FCPA) enforcement action against employees of a US broker-dealer, who are alleged to have bribed a Venezuelan government official to direct brokerage to the firm. The case is one of only a handful of financial services industry FCPA enforcements and is a reminder of the government’s interest in extending the law’s reach to all economic sectors. This client publication summarizes recent events and provides suggestions on how the banking and finance sector can manage its FCPA risks.
22 Apr 2013
The first quarter of 2013 was marked by various efforts by the Treasury Department’s Office of Foreign Asset Control (“OFAC”) to provide some much-needed guidance and support to persons attempting to comply with ever more complicated US sanctions, including the launch of an updated online search tool.
20 Mar 2013
Section 219 (codified as Section 13(r) of the Securities Exchange Act) has been in effect for six weeks. During this time, more than 100 SEC-registered reporting issuers have made required disclosures regarding their Iran or SDN-related activity.
14 Feb 2013
As of noon today, eight US-registered issuers have made disclosures of Iran-related activities pursuant to the new reporting requirements under Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (“Section 219”).