The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent...more
12/4/2024
/ Compliance ,
Corruption ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Policy ,
Health Insurance ,
Iran ,
Iran Sanctions ,
ITSR ,
Life Insurance ,
MetLife ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Politically Exposed Person (PEPs) ,
Sanction Violations ,
U.S. Treasury ,
United Arab Emirates (UAE) ,
White Collar Crimes
The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more
9/12/2024
/ Bribery ,
Compliance ,
Corporate Counsel ,
Corporate Misconduct ,
Corruption ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Subsidiaries ,
Internal Controls ,
John Deere ,
Securities and Exchange Commission (SEC) ,
Statutory Violations ,
White Collar Crimes
On August 30, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) announced the settlement of a record $200 million administrative enforcement action with RTX Corporation—a multinational...more
9/6/2024
/ Corporate Counsel ,
Corruption ,
Defense Sector ,
Department of Defense (DOD) ,
Directorate of Defense Trade Controls (DDTC) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
ITAR ,
Statutory Violations ,
White Collar Crimes
On July 3, 2024, the Council of the European Union (“EU Council”) officially promulgated a new set of best practices (“best practices” or “guidance”) for organizations seeking to comply with the latest sanctions regulations...more
On May 30, 2024, following passage by the European Parliament in late April, the European Council officially adopted a set of rules that modernizes and harmonizes money laundering and terrorist financing (“AML/CFT”)...more
6/19/2024
/ AML/CFT ,
Anti-Corruption ,
Anti-Money Laundering ,
Compliance ,
Corruption ,
Cross-Border Transactions ,
EU ,
EU Directive ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
Money Laundering ,
New Rules ,
Terrorism Funding ,
Terrorist Financing Regulations ,
White Collar Crimes
Wabtec Corporation (“Wabtec”)—a global manufacturer and supplier of rail technology headquartered in Pittsburgh, Pennsylvania—recently settled an administrative enforcement proceeding with the U.S. Department of Commerce’s...more
2/8/2024
/ Antiboycott Requirements ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Corruption ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Regulatory Violations ,
US Trade Policies
On December 31, 2021, President Joseph R. Biden, Jr. signed the the Uyghur Forced Labor Prevention Act (“UFLPA”) into law to address the ongoing exploitation of the ethnic minority Uyghur population by the government of the...more
1/25/2024
/ China ,
Compliance ,
Corruption ,
Customs and Border Protection ,
Entity List ,
Exploitation ,
Forced Labor ,
Foreign Policy ,
Human Rights ,
Popular ,
Supply Chain ,
Uyghur Forced Labor Prevention Act (UFLPA)
On December 14, 2023, Congress passed the Foreign Extortion Prevention Act (“FEPA”) in an effort to address certain deficiencies inherent in the current iteration of the Foreign Corrupt Practices Act (“FCPA”), as part of the...more
1/9/2024
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Compliance ,
Corruption ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
NDAA ,
Proposed Regulation ,
Regulatory Agenda ,
White Collar Crimes
On September 27, 2023, the United States Department of Commerce’s Office of Antiboycott Compliance, a division of the Bureau of Industry and Security (“BIS”), publicized an unanticipated and relatively rare enforcement action...more
9/13/2023
/ Antiboycott Requirements ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Corruption ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Popular ,
US Trade Policies