News & Analysis as of

Sanctions Enforcement Actions

WilmerHale

UK Sanctions - Mid-Year Update

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This alert discusses two recent significant developments at either end of the UK sanctions spectrum, covering off designation (a recent Supreme Court decision providing important guidance as to the assessment of...more

A&O Shearman

HMT consults on reforms to OFSI civil enforcement processes

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HM Treasury (HMT) has published a consultation paper on proposed reforms to the Office of Financial Sanctions Implementation's (OFSI) civil enforcement processes. The aim is to improve the efficiency, transparency and...more

Stankie Law

Quarterly Trade Compliance Update – July 2025

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Each quarter, I send my clients a trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. In addition to a variety of ad hoc...more

Husch Blackwell LLP

DOJ Declines to Prosecute Private Equity Firm After Self-Disclosure Related to Acquired Company

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Last year, the Department of Justice (DOJ) National Security Division (NSD) updated its Enforcement Policy for Business Organizations to include guidance related to voluntary self-disclosures in connection with acquisitions....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

The Volkov Law Group

Interactive Brokers Settles with OFAC for $11.8 Million for Violations of Multiple Sanctions Programs

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced on July 15, 2025, that Interactive Brokers LLC (“IB”)—a globally active electronic brokerage firm headquartered in Greenwich,...more

Thomas Fox - Compliance Evangelist

Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting...more

The Volkov Law Group

Episode 378 — Update on Export and Sanctions Enforcement Cases

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The Trump Administration is aggressively pursuing export controls and sanctions enforcement. In two separate cases, the Treasury Department’s Office of Foreign Asset Control and the Commerce Department’s Bureau of Industry...more

Mayer Brown

FinCEN's First Strike: New Section 311 Powers Target Mexican Financial Institutions Under FEND Off Fentanyl Act

Mayer Brown on

In this episode, host Lauren Pryor and her colleagues discuss the recent actions by FinCEN, which designated three Mexican financial institutions as primary money laundering concerns under the expanded Section 311 authority,...more

The Volkov Law Group

Episode 378 -- Update on Export Controls and Sanctions Enforcement

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What happens when companies ignore red flags, bypass legal advice, and underestimate the reach of U.S. export laws? In this episode, Michael Volkov unpacks two major enforcement actions from the Department of Commerce’s...more

Troutman Pepper Locke

M&A and Global Compliance Lessons From OFAC’s Settlement With Key Holding

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On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) reached a settlement with Key Holding, LLC (Key Holding) concerning its non-U.S. subsidiary’s violations of the Cuban Assets...more

Kelley Drye & Warren LLP

Trump Issues Reciprocal Tariff Letters to 8 Additional Trade Partners

On Wednesday, July 9, President Trump issued letters to eight additional trade partners notifying them of their country-specific reciprocal tariff rates that will go into effect on August 1. An updated reciprocal tariff chart...more

Barnea Jaffa Lande & Co.

Israel Securities Authority Pecuniary Sanctions: Enforcement Tool or Rights Violation?

The Israel Securities Authority (ISA) has recently begun to take a clearly more aggressive approach toward administrative enforcement. Originally, pecuniary sanctions were intended to provide a swift, proportional, and...more

Jones Day

Landmark European Commission Cartel Fines on No-poaching Agreements and Minority Shareholdings

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European Commission ("EC") issues its first fining decision for a no-poach agreement, and also sanctions for the first time the exchange of sensitive information between a company and its competing, non-controlling minority...more

White & Case LLP

DOJ Already Filing Material Support Charges After Designating Cartels as Foreign Terrorist Organizations

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On February 20, 2025, the United States designated eight cartels and transnational criminal organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). Since then, the US...more

Davies Ward Phillips & Vineberg LLP

A Strong Signal: AMF Adopts a Policy Supporting Self-Reporting and Cooperation

The Autorité des marchés financiers (AMF), the body responsible for enforcing Québec’s legislation concerning the financial sector, recently adopted a Self-Reporting and Cooperation Policy. The policy, adopted on May 20,...more

Skadden, Arps, Slate, Meagher & Flom LLP

EU and UK Sanctions: New Sanctions Packages and Other Key Developments June 2, 2025

The EU and UK sanctions regimes on Russia continue to expand as both jurisdictions seek to increase pressure on President Putin. As with previous recent packages, Russia’s military, energy and financial sectors have again...more

Dacheng

Regulatory Escalation in Pharma Sector: China Imposes First Executive Sanctions in a Cartel Case

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On May 9, 2025, the Tianjin Municipal Administration for Market Regulation (“Tianjin AMR”) announced administrative penalties against four manufacturers of dexamethasone sodium phosphate (“DSP”) active pharmaceutical...more

DarrowEverett LLP

The DOJ’s New White-Collar Agenda: Implications for Businesses

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On May 12, 2025, the Department of Justice (the “DOJ”) released its criminal—and, more specifically, white collar crime enforcement—initiatives under the current administration. This is typical each time new leadership...more

Troutman Pepper Locke

NCAA Imposes Harsh Sanctions on Fordham University Men’s Basketball for Recruiting Violations

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On April 22, the National Collegiate Athletic Association (NCAA) handed down harsh penalties on Fordham University’s men’s basketball program in what it referred to as a Level II “Major Infractions Case” via a negotiated...more

Secretariat

Rebuilding Ukraine — April 2025 Edition

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Welcome to Secretariat’s April 2025 edition of Rebuilding Ukraine, where we explore the evolving landscape of Ukraine’s reconstruction, the challenges ahead, and the opportunities emerging. Stay informed with our insights on...more

Jones Day

First Circuit Reverses SEC Win in $93 Million Investment Adviser Disclosure Case

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The court rejects the SEC's per se materiality argument and requires proof of a causal connection between the defendant's allegedly inadequate disclosures and purported unlawful profits....more

Cozen O'Connor

New Presidential Memo: Preventing Abuses of the Legal System and the Federal Court

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OVERVIEW: •On March 22, 2025, the Trump administration published a Presidential Memorandum titled: Preventing Abuses of the Legal System and the Federal Court. •The memo directs Attorney General (AG) Pam Bondi to seek...more

Mayer Brown

UK Weekly Sanctions Update - Week of March 3, 2025

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In this weekly update, we summarise the most notable updates in the UK sanctions world...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Sanctions: A New Package, Guidance and Legal Clarifications

The future of international sanctions on Russia is not settled. Whilst the representatives of the US and Russia met in Saudi Arabia on 18 February 2025 to discuss possible avenues to peace in Ukraine, the foreign ministers of...more

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