OFAC Imposes Blocking Sanctions on PdVSA

Authors: Susannah Cogman, Partner, London; Daniel Hudson, Partner, London; Jonathan Cross, Counsel, New York; Geng Li, Associate, New York; and Christopher Milazzo, Associate, New York. On January 28, 2019, the US Department of the Treasury’s Office of Foreign Assets Control… Read more

Corporate Crime update – December 2018

Welcome to the December 2018 edition of our corporate crime update - our round up of developments in relation to corruption, money laundering, fraud, sanctions and related matters. This month, we would like to wish all of our regular readers a… Read more

EUROPEAN COMMISSION ANNOUNCES “NO DEAL” CONTINGENCY ACTION PLAN

The European Commission has announced that it has started implementing its Brexit “no deal” Contingency Action Plan given the continuing uncertainty regarding ratification of the Withdrawal Agreement in the UK. This follows the Commission's communication of 13 November 2018 which… Read more

HKMA set to turn up the heat on bank culture in 2019

On 19 December 2018, the Hong Kong Monetary Authority (HKMA) announced that it will introduce supervisory measures (Supervisory Measures) focused specifically on measuring authorised institutions’ (AI) progress in implementing reforms to their culture. The Supervisory Measures include requiring AIs to… Read more

Renewed focus on compensation to address misconduct risk

The Financial Stability Board (FSB) released on 23 November 2018 its recommendations on the types of data regulators should be collecting from financial institutions (FIs) regarding compensation tools, as part of its workplan to address misconduct risk in FIs. This… Read more

Corporate Crime autumn update 2018

Welcome to the autumn 2018 edition of our corporate crime update - our round up of developments in relation to corruption, money laundering, fraud, sanctions and related matters. Our update now covers a number of jurisdictions. For the full update on each jurisdiction, please… Read more

Brexit Final Political Declaration: Nothing [new] to see here?

On financial services, the final political declaration contains essentially the same three points as in last week's outline political declaration (the implications of which were discussed in our blog post of 15 November, available here), although there is some limited… Read more

Second Wave of United States Sanctions Against Iran Re-Imposed

Following President Trump’s decision on May 8, 2018 to withdraw the United States from the Joint Comprehensive Plan of Action (“JCPOA”), the US government announced that it would re-impose pre-JCPOA nuclear-related Iran sanctions (both primary and secondary) that were lifted… Read more

SANCTIONS CLAUSES IN A CHANGING SANCTIONS REGIME

How far can a sanctions clause protect a party from having to perform their contractual obligations - and in the case of Iran-related sanctions concerns, how does this interact with the Blocking Regulation? In Mamancochet Mining Limited v Aegis Managing Agency… Read more

OFSI publishes Annual Review

On 5 October 2018, HM Treasury's Office of Financial Sanctions Implementation (OFSI) published its Annual Review for the 2017-18 financial year. This is the first such review published by OFSI and provides an overview of OFSI's activities in 2017-18, as… Read more

Thailand’s new anti-corruption law targets foreign corporates

Thailand is the latest Asian jurisdiction to strengthen its anti-graft legislation. India, Japan, Singapore, Malaysia, Vietnam and China have all introduced anti-bribery legislation this year. The net effect is an uptick in the local enforcement risk for corporates operating in… Read more

HKMA endorses benefits of cooperation

The Hong Kong Monetary Authority (HKMA) has recently released its first Guidance Note on Cooperation with the HKMA in Investigations and Enforcement Proceedings. In releasing the guidance note, the HKMA has expressly signalled its desire to encourage and facilitate cooperation,… Read more

Corporate Crime summer update 2018

Welcome to the summer 2018 edition of our corporate crime update - our round up of developments in relation to corruption, money laundering, fraud, sanctions and related matters over July and August.  ... Read more

The Rise of the Crypto Hedge Fund: Opportunities and Challenges

The extraordinary returns generated by cryptocurrencies have led to a frenzy of investment activity and interest from investors. Several new crypto hedge funds have emerged, and cryptocurrency is fast establishing itself as a mainstream asset class. However, numerous operational and… Read more

Do we need a new duty of care in financial services?

On 17 July 2018, the FCA published a paper on its Approach to Consumers (the Approach), accompanied by a discussion paper DP18/5 (the DP) on the possible introduction of a new duty of care and other alternative approaches (a New Duty). The… Read more