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Series: How to Respond to the Threat of Trade Secret Loss
The authors would like to thank Nicole Brenner for her contribution to this post. Trade secrets offer companies an invaluable advantage over competitors, but only if the company maintains secrecy and...
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Russian Sanctions Update: Will “Biting” Eighth EU Sanctions Package Prohibit...
“Russia should not benefit from European knowledge and expertise.” That is the view of European Commission (“EC”) President Ursula von der Leyen, who recently proposed an eighth package of sanctions...
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OFAC Sanctions Virtual Currency Mixer “Tornado Cash”
On August 8, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned virtual currency mixer Tornado Cash for having laundered more than USD 7 billion worth of...
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Corporate Transparency Act – FinCEN Issues Final Rule for Beneficial...
We recently shared an alert covering The National Defense Authorization Act for Fiscal Year 2021 (NDAA), which became law on January 1, 2021. The NDAA included significant reforms to the U.S....
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Welcome to Global Investigations & Compliance Review
This year has brought remarkable change around the globe – including new administrations, changing regulatory approaches, conflicts, and rapidly evolving global sanctions. Staying on top of how these...
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Corporate and White-Collar Enforcement in 2023–24
As 2022 comes to a close, is it possible to predict a trend for corporate and white-collar enforcement by the U.S. Department of Justice in 2023? Yes: enforcement will increase in 2023, and it will...
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Compliance Risks for Remote and Hybrid Working Models
With the cold and flu season underway and COVID-19 still ever-present, it is a good time to take stock of the potential risks that come with working remotely. Following the lifting of pandemic...
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Rule 10b5-1 Application and Enforcement
On March 1, 2023, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) demonstrated continued interest in investigating insider trading by company executives who...
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Supreme Court Restricts the Scope of the Aggravated Identity Fraud Statute
Earlier this month, the Supreme Court of the United States decided Dubin v. United States, No. 22-10, 2023 WL 3872518, at *1 (U.S. June 8, 2023), in favor of the defendant. Justice Sonia Sotomayor...
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New UAE Rule Regarding the Mandatory Attestation of Import Invoices Could...
The United Arab Emirates (“UAE”) has recently implemented a new compliance requirement related to the international importation of goods. Specifically, pursuant to UAE Cabinet Resolution No. 38 of...
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Wolfsberg Group Releases Guidance on Negative News Screening
The Wolfsberg Group, an association of thirteen global banks which develops frameworks and guidance for the management of financial crime risks, particularly with respect to KYC, AML, and CFT...
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Increased Corporate Transparency in the Cayman Islands
The Cayman Islands, a British overseas territory, has long been recognized as one of the world’s leading providers of institutionally focused financial services and a preferred destination for the...
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New 10-Year Statute of Limitations for U.S. Sanctions Violations
On April 24, 2024, President Biden signed into law H.R. 815[1], an emergency supplemental appropriations law, that provides $95.3 billion in military aid to U.S. allies and requires the divestiture of...
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End of the Chevron Era: The Future of Agency Enforcement Shifts to Courts
With its second of two landmark decisions impacting the future of federal agency enforcement, SCOTUS struck down the Chevron decision last week. In a 6-3 decision in Loper Bright Enterprises v....
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WEBINAR- The 2024 Revolution in Administrative Law: Chevron and Beyond
Join #TeamSPB’s Ben Glassman, Keith Bradley and Patricia Doersch for a timely webinar on the major decisions recently issued by SCOTUS. The panel will cover each of the recent decisions (Loper Bright...
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Recent DFSA Enforcement Activity and Future Priorities
In this article, we summarize the trends that have emerged from enforcement actions published between 2022 and the present day by the Dubai Financial Services Authority (the “DFSA”). DFSA Enforcement...
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Does the Seventh Amendment Limit State Administrative Adjudication?
At Global Investigations and Compliance Review, we’ve been keeping close tabs on the fallout from the Supreme Court decisions at the end of June. We mentioned in a previous post that the SEC v....
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OFAC Guidance on the Statute of Limitations Extension
OFAC will only apply new 10-year statute of limitations for a violation that occurred after April 24, 2019; if the violation occurred on or before April 24, 2019, OFAC will only apply the previous...
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Insider Dealing: Increasing Scope and Greater Focus from UK and US...
The UK and US enforcement agencies have been actively pursuing insider dealing (“insider trading”, in US parlance) since the COVID-19 pandemic ended. The UK and US have different securities...
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Non-Financial Misconduct in the UK: A Thoughtful Initiative or a Hastily...
Non-financial misconduct (“NFM”) within the financial sector has posed significant challenges for the U.K. Financial Conduct Authority (“FCA”) for several years. The FCA handbook prescribes that...
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