Monthly Archives: February 2022

Review of Sanctions and Export Controls Imposed in Response to Russia’s Invasion of Ukraine

Key Takeaways: 

  • The initial wave of sanctions targeted Russian banks and the financial industry plus individual “inner circle” elites, with more sanctions likely to follow in the coming weeks as events unfold.
  • Broad restrictions on debt and equity transactions with certain entities in the Russian financial, energy, and infrastructure sectors.
  • Expanded export controls, including foreign-direct product rule restrictions, new license requirements, and Entity List designations impact a wide range of exports to Russia.…
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SEC Enforcement in 2022: A Look Ahead

This is the sixth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in sanctions & export controls enforcement. Up next: trends in False Claims Act enforcement.

Takeaways:

  • The SEC Division of Enforcement’s increasingly aggressive pursuit of investigations and enforcement actions will continue in 2022.…
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Office of the Massachusetts Attorney General – 2022 Preview

This is the fourth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in tax enforcement. Up next: trends in sanctions & export controls enforcement.

2022 is shaping up to be an interesting year for the Office of the Massachusetts Attorney General. It marks Maura Healey’s final year as AG as she gears up for her run for governor. … More

Possible International Trade Consequences of Further Escalation of Conflict in Ukraine

Key Takeaways:

  • The U.S., EU, and UK are coordinating a significant sanctions and export controls package to be implemented if Russia takes further action in Ukraine.
  • Restrictions are likely to target key Russian industries including finance, energy, and defense and would be far more severe and far-reaching than past sanctions.
  • New export controls could include restrictions on foreign-produced items made using U.S.-origin technology or software,…
  • More

Possible International Trade Consequences of Further Escalation of Conflict in Ukraine

Key Takeaways:

  • The U.S., EU, and UK are coordinating a significant sanctions and export controls package to be implemented if Russia takes further action in Ukraine.
  • Restrictions are likely to target key Russian industries including finance, energy, and defense and would be far more severe and far-reaching than past sanctions.
  • New export controls could include restrictions on foreign-produced items made using U.S.-origin technology or software,…
  • More

Criminal Tax Violations: 2022 Enforcement Trends

This is the third post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in anti-corruption. Up next: State AG enforcement trends.

  • While the volume of IRS enforcement actions has waned, it may soon increase.
  • Even at current relatively low audit and investigation levels, the IRS remains aggressive in the cases it does pursue.…
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Anti-Corruption in 2022: A Look Ahead

This is the second post in this year’s series examining important trends and new development in white collar law and investigations.  Our previous post discussed health care enforcement. Up next: trends in tax enforcement.

As the Biden administration moves into its second year, we anticipate both an increase in U.S. anti-corruption enforcement activity, and a broader, whole-of-government approach that seeks to encourage and reward international partners for their efforts in combatting corruption. … More

Health Care Enforcement – A Look Ahead

This is the first post in this year’s series examining important trends in white collar law and investigations. Join us in the weeks ahead as we provide updates on new developments and emerging trends in a number of white collar spaces. Up next: trends in anti-corruption.

A perennial focus of regulators, health care fraud enforcement remained active in 2021 and is expected to continue in the year ahead.… More

Second Circuit’s Rejection of Fraud Theory in LIBOR Manipulation Case May Have Far-Reaching Implications

In a long-awaited decision on January 27, 2022, a unanimous panel of the U.S. Court of Appeals for the Second Circuit reversed the convictions of Deutsche Bank (DB) derivatives traders Matthew Connolly and Gavin Black in a fraud case arising from the alleged manipulation of the London Interbank Offered Rate (LIBOR). In United States v. Connolly,[1] the two traders were charged with pressuring the DB department responsible for submitting estimates of interest rates used to calculate LIBOR to benefit the bank’s trading positions.… More

CBP Focus on Forced Labor in Malaysia and the Seafood Industry Continues with New WRO and Findings

Key Takeaways:

  • U.S. Customs and Border Protection (“CBP”) trend of enforcement against forced labor in supply chains continues and forced labor in Malaysia and on deepwater fishing vessels remain key areas of focus for CBP
  • New WRO blocks import of rubber gloves from Malaysian producer
  • Two new findings of forced labor issued on palm oil and seafood products

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On Friday,… More