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”).
29 Jan 2013
Partner Philip Urofsky
(Washington, DC-Litigation) and associate Jessica Bartlett (New York-Litigation) have published an article, titled "Effective Corporate Compliance and the Irrelevant 'Foreign Official' Debate," in the January 11, 2013 edition of Bloomberg BNA's White Collar Crime Report
7 Jan 2013
The final quarter of 2012 was marked by US and EU efforts to prevent Iran from circumventing existing sanctions, an increasingly extraterritorial bent to US sanctions, and record breaking sanctions-related settlements by foreign financial institutions with US authorities.
2 Jan 2013
This bi-annual Shearman & Sterling publication provides insightful analysis of recent trends and patterns and an invaluable compendium of all Foreign Corrupt Practices Act (FCPA) enforcement actions and private actions.
17 Dec 2012
In our continuing series on Section 219, we now move beyond interpreting the requirements of Section 219 to the mundane yet important task of complying with these new requirements.
6 Dec 2012
On December 4, 2012, the staff of the SEC’s Division of Corporation Finance released compliance and disclosure interpretations reflecting the Staff’s views on frequently asked questions relating to Section 13(r) of the Exchange Act.
15 Nov 2012
On November 14, 2012, the US Department of Justice and the Securities and Exchange Commission issued the long-promised guidance outlining their interpretation of critical elements of the US Foreign Corrupt Practices Act (FCPA), providing some helpful guidance concerning the design and application of anti-corruption compliance programs, and explaining some of their enforcement policies concerning prosecution and resolution.
8 Nov 2012
Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 mandates additional disclosure requirements for US-registered issuers concerning certain Iran-related activities and, under a plain reading of the statute, certain activities with non-Iran-related persons or entities listed on the US Department of the Treasury’s Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List (SDNs).
What makes a statute effective—enforcement statistics such as convictions and fines or whether it is, in practice and in the field, observed by those whose conduct it targets?
25 Oct 2012
On October 9, 2012, President Obama issued an Executive Order implementing certain provisions of the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRA”).