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Bracewell LLP

FinCEN's Cartel Crackdown on Three Mexican Financial Institutions: Implications for US Financial Transactions

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It just got much riskier to do business in Mexico. On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a novel set of orders finding three financial institutions in...more

Baker Botts L.L.P.

Beyond the Fine: What Financial Gatekeepers Must Learn from Interactive Brokers’ OFAC Settlement

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has significantly increased its focus on sanctions compliance for “financial gatekeepers,” including financial institutions and other firms...more

Troutman Pepper Locke

Major OFAC Penalty for US Venture Capital Fund – Key Takeaways

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On June 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a civil penalty of approximately $216 million on GVA Capital Ltd., a venture capital firm based in San Francisco, for...more

Thomas Fox - Compliance Evangelist

10 For 10: Top Compliance Stories For The Week Ending, March 22, 2025

Welcome to 10 For 10, the podcast that brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance, brings you the compliance professional and the compliance stories you need to...more

Mintz

State Attorneys General Take Aim at DEI Policies at Six Major Financial Institutions

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On January 23, 2025, a coalition of Attorneys General from ten states, led by AG Ken Paxton of Texas, penned a letter to six major U.S. financial institutions, warning that their embrace of “race-and-sex-based quotas” and...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Sanctions Puzzle: Key Areas To Watch in 2025 and Beyond

The past weeks and months have brought about tremendous political change in the West, as we move toward a new U.S. administration, a new College of Commissioners in Brussels and a new Polish presidency of the Council of the...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

K&L Gates LLP

Message Received: SEC Zeros In On Off-Channel Communication

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INTRODUCTION - On 7 February 2023, the U.S. Securities and Exchange Commission (SEC) Division of Examinations (the Division) released its 2023 examination priorities. As expected, the Division’s priorities highlight areas...more

StoneTurn

No One Wants a Monitor, But… Part 3: Lessons Learned from Monitorships

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What was it like to be at one of the world’s largest companies while it was subject to a monitor? In this episode, Cindy Moehring highlights some of the key lessons learned from working with a monitor, and taps into Michele...more

StoneTurn

No One Wants a Monitor, But… Part 2: Working with a Monitor

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Monitorship: a term typically met with fear, but it doesn’t have to be. What’s at stake when a monitor comes on board? Are there global considerations at play? Cindy Moerhing, Michele Edwards and Emilia Drozda highlight keys...more

StoneTurn

No One Wants a Monitor, But… Part 1: The Landscape

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As the regulatory landscape changes across the globe, how will monitorships fit into the puzzle? In this episode, Cindy Moehring, former Chief Ethics and Compliance Officer (U.S.) for Walmart, sits down with StoneTurn’s...more

UB Greensfelder LLP

[Webinar] SEC Update: Reg BI, Enforcement Activity, and the Willfulness Standard - February 11th, 2:00 pm - 3:00 pm EST

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Join Heidi E. VonderHeide as she discusses how Regulation Best Interest is being implemented, examines post-effective date guidance and activity by the regulators, and shares what to expect during 2021 exams. Heidi will also...more

Pillsbury Winthrop Shaw Pittman LLP

The SPAC Explosion: Beware the Litigation and Enforcement Risk

SPACs have seen exponential growth in 2020, but SPAC sponsors, investors and targets should beware the scrutiny de-SPAC transactions are receiving from the plaintiffs’ bar and the SEC. 2020’s SPAC IPO explosion will...more

Orrick, Herrington & Sutcliffe LLP

DOJ Updates Its Approach to Encourage Voluntary Self-Disclosures of Export Control and Sanctions Violations

On December 13, 2019, the National Security Division (“NSD”) of the U.S. Department of Justice (“DOJ”) released a revised enforcement policy (“the Policy”) meant to encourage companies to voluntarily self-disclose potentially...more

The Volkov Law Group

Barclays Agrees to Pay the SEC $6.3 Million to Settle FCPA Offenses for Hiring of Relatives of Foreign Officials in Asia

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Barclays joined the club of global financial institutions settling FCPA violations for hiring of relatives of foreign officials in Asia.  Barclays agreed to disgorge $3.8 million and paid prejudgment interest of nearly $1...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Adds Iranian Bitcoin Exchangers’ Names and Wallet Addresses to SDN List, Ushers in “New Approach” to Sanctions Enforcement

• On November 28, 2018, OFAC designated two Iran-based individuals who helped exchange cryptocurrency (bitcoin) into fiat currency on behalf of alleged ransomware perpetrators who targeted U.S. businesses and municipal...more

Sheppard Mullin Richter & Hampton LLP

The Numbers Don’t Lie: The SEC Pursues a More Streamlined Enforcement Agenda

One of the most eye-catching items in the recently released 2017 Annual Report of the Enforcement Division of the Securities and Exchange Commission (SEC or the Commission) is the significant decline in enforcement activity...more

Skadden, Arps, Slate, Meagher & Flom LLP

Government Enforcement Investigations – What You Need to Know in 2018

On October 4, 2017, Skadden presented the seminar “Government Enforcement Investigations – What You Need to Know in 2018.” Skadden partners Ryan Junck and Elizabeth Robertson, both based in London, moderated the panel...more

The Volkov Law Group

Lessons Learned From FCPA Enforcement Against JP Morgan for Sons and Daughters Referral Program

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Last week, the Justice Department and the SEC finally brought to a close the Sons and Daughters or Princelings investigation. Pending investigations against four other companies still remain to be resolved....more

K&L Gates LLP

D.C. Circuit Appears Poised to Overturn First CFPB Enforcement Action to Reach the Court: Five Key Takeaways From Yesterday’s Oral...

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Major financial firms almost never litigate with their regulators. As a result, regulators often take aggressive enforcement positions with little fear of judicial scrutiny. That’s been especially true for the Consumer...more

Davis Wright Tremaine LLP

Violation of OFAC Reporting Requirements: “No Harm, No Foul”? No Way!

A recent enforcement action by the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) against MasterCard International Incorporated (“MasterCard”) stands as a reminder of the importance of strictly...more

Dorsey & Whitney LLP

When is an Administrative Action Barred by the Dodd-Frank Act’s Three-Year Statute of Limitations? Never, According to the CFPB

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Corporate defendants are entitled to the protections afforded by statutes of limitations, which bar claims for conduct long-past and are “vital to the welfare of society.” See, e.g., Gabelli v. S.E.C., 133 S. Ct. 1216, 1221...more

Perkins Coie

SEC’s Increased Cybersecurity Enforcement and How to Reduce Your Risks

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The SEC announced last week that an investment adviser had agreed to settle charges that it failed to take required steps to protect against and respond effectively to a cybersecurity breach. The action comes on the heels of...more

Carlton Fields

Federal Court Holds Neither Janus, Nor Statute of Limitations Shields Alleged “Pump-And-Dump” Fraudsters From Civil Liability in...

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In another example of the limits to which defendants may successfully rely on the Supreme Court’s decision in Janus Capital Group, Inc. v. First Derivative Traders, 131 S. Ct. 2296 (2011), earlier this summer, District Judge...more

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