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U.S. Cracks Down on Sanctions Evasion

On March 2, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), the Department of the Treasury’s Office of Foreign Asset Control (OFAC) and the Department of Justice issued a joint compliance note...more

2023 Report on FINRA’s Examination and Risk Monitoring Program

On January 10, 2023, the Financial Industry Regulatory Authority (“FINRA”) issued its 2023 Report on FINRA’s Examination and Risk Monitoring Program (the “Report”). The Report, which is a more comprehensive version of FINRA’s...more

SEC’s Enforcement Actions and Public Pronouncements Reinforce Approach on Digital Assets

On September 17, 2022, both the Securities and Exchange Commission and Ripple Labs, Inc. (with its Executive Chairman and CEO) filed motions for summary judgment in the SEC’s suit alleging that Defendants sold billions of...more

Former Cryptocurrency Exchange Manager Indicted by DOJ and Charged by SEC: Is It 'Regulation by Enforcement'?

On July 21, 2022, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) for the first time brought insider trading charges involving cryptocurrency assets. The SEC and DOJ charged a former...more

SEC’s Division of Examinations Issues Risk Alert Regarding MNPI-Related Compliance Issues for Investment Advisers

On April 26, 2022, the Division of Examinations (the “Division”) of the Securities and Exchange Commission issued a Risk Alert listing notable examples of deficiencies that its staff has identified regarding investment...more

DOJ Will Strengthen Response to Corporate Crime: Major Policy Changes Signal Return to Tougher Enforcement and Individual...

On October 28, 2021, at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa O. Monaco announced revisions to the Department of Justice’s policies, all designed to strengthen...more

Sanctions Roundup: Third Quarter 2021

The Biden Administration this quarter announced fewer targeted sanctions, but issued several “whole of government” advisories regarding sanctions risks associated with China-related business dealings, as well as virtual...more

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