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Sanctions Enforcement Actions Corporate Counsel

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

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

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

Skadden, Arps, Slate, Meagher & Flom LLP

OFSI Issues First Monetary Penalty for Breach of Sanctions Imposed on Russia in Response to Its Invasion of Ukraine

On 27 September 2024, the UK’s financial sanctions regulator, the Office of Financial Sanctions Implementation (OFSI), announced that it had issued its first monetary penalty for a breach of UK financial sanctions imposed...more

McDermott Will & Schulte

European Privacy Risk Exposure

2022 was yet another eventful year in terms of GDPR compliance. The continued evolution of the enforcement landscape, with increasing number of sanctions and individuals exercising their rights required time and attention...more

Proskauer - Minding Your Business

The Sound of “Silent Attorneys”: DOJ Alleges Google Fakes Attorney-Client Privilege by CCing Lawyers Who Never Respond

If a request for legal advice goes unanswered, is it really a request for legal advice? According to the U.S. Department of Justice and several state attorneys general (“DOJ Plaintiffs”) in an antitrust action against...more

Fenwick & West LLP

OFAC Helps Those Who Help Themselves: How a Ransomware Response Plan Can Help Avoid Sanctions Enforcement for Ransom Payments

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Many companies have a “no ransomware payment” stance until faced with a ransomware attack, especially an attack that causes significant business disruption. At that point, the company may reconsider its stance (or at least...more

Morrison & Foerster LLP

Lessons Learned From OFAC’s 2020 Enforcement Actions

As we previously wrote in our OFAC 2020 Year in Review, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) saw a drop in enforcement activity in 2020, likely due to the massive year it had in 2019 and...more

White & Case LLP

GDPR Guide to National Implementation - A practical guide to national GDPR compliance requirements across the EEA

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Foreword - European data protection laws have made significant strides in the last two decades. Privacy and data protection laws have undergone dramatic changes over the last 20 years, in a race to keep up with technology....more

A&O Shearman

SEC, Under New Safe Harbor, Awards More Than $2.2 Million To Whistleblower Who First Reported To Another Federal Agency

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On April 5, 2018, the Securities and Exchange Commission (“SEC”) announced a whistleblower award of more than $2.2 million in connection with a report of misconduct. The whistleblower, a former company insider, first reported...more

Foley & Lardner LLP

A Review of Recent Whistleblower Developments

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SEC Brings First Stand-Alone Whistleblower Retaliation Enforcement Action - On September 29, 2016, the U.S. Securities and Exchange Commission (SEC) brought its first stand-alone whistleblower retaliation case under...more

WilmerHale

SEC Administrative Case Reinforces Current Emphasis on Internal Controls

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Consistent with its current focus on internal control over financial reporting (ICFR), the Securities and Exchange Commission recently sanctioned a company and individuals for failing to adequately evaluate and audit the...more

K&L Gates LLP

How to Conduct Internal Investigations Outside the United States

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Think of a U.S.-headquartered multinational when it receives an allegation of serious misconduct at one of its overseas operations. Maybe the company whistleblower hotline just got a tip that a secretary in the Buenos Aires...more

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