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 (“OFAC”) announced the designation of Venezuelan state-owned oil producer Petroleos de Venezuela, S.A. (PdVSA) as … Read more

US Appellate Court Rejects DOJ’s Expansive Use of Conspiracy for FCPA Jurisdiction

On August 24, 2018, the Second Circuit Court of Appeals rejected the government’s broad interpretation of the jurisdictional reach of the Foreign Corrupt Practices Act (“FCPA”) and held the government could not use aiding and abetting and conspiracy theories to prosecute an individual who was not otherwise covered by the FCPA. Specifically, the Court held … Read more

US OFAC issues guidance on sanctions compliance services

New guidance issued by the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) clarifies that U.S. attorneys, compliance personnel, and others are not prohibited from providing services related to compliance with U.S. sanctions laws, even where sanctions would otherwise prohibit U.S. persons from direct or indirect involvement in the underlying business activities.  To read … Read more

US further eases sanctions against Cuba

On 14 October 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) again announced significant amendments to the Cuban Assets Control Regulations (CACR) and Export Administration Regulations (EAR). This is the second round of amendments made to the Cuba … Read more

Market abuse update – July 2016

The Market Abuse Regulation (MAR) and the Criminal Sanctions (Market Abuse) Directive came into application in Europe on 3 July 2016.  Various outstanding pieces of secondary legislation were published in the Official Journal shortly before then, and further material has emerged since 3 July. ESMA published final form guidelines in relation to delay in disclosure of … Read more

Market abuse update – April 2016

This will be our last quarterly Market Abuse update before 3 July 2016, the date when both the new Market Abuse Regulation and the Criminal Sanctions (Market Abuse) Directive come into application across Europe. Some significant pieces of the regulatory jigsaw have yet to be slotted into place, so we have set out the current … Read more

DOJ announces new FCPA pilot program to promote self-reporting

On April 5, 2016, the DOJ announced that it is launching a one-year pilot program for FCPA enforcement as a step to continue its effort to target FCPA violations. The program aims to motivate companies to voluntarily disclose FCPA-related misconduct by making it transparent that a company has to voluntarily self-report its FCPA misconduct to … Read more

OFAC issues regulations implementing new sanctions targeting Hizballah

On 15 April 2016, the US Department of the Treasury’s Office of Foreign Assets Control ("OFAC") issued regulations to implement the Hizballah International Financing Prevention Act of 2015, authorizing secondary sanctions against foreign financial institutions ("FFIs") that facilitate or conduct certain activities for the benefit of Hizballah. Read more