Monthly Archives: March 2022

Key Takeaways:

• U.S. imposes sanctions on Duma members, board members and executives of sanctioned Russian banks, and defense companies
• UK sanctions 65 individuals and entities, focusing on Russian oligarchs, financial institutions, and senior executives of state-owned enterprises
• OFAC issues new FAQ clarifying that gold transactions fall within the scope of existing Russia-related sanctions

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U.S. Sanctions

The U.S.… More

Today, the Securities & Exchange Commission voted 3 to 1 in favor of adopting a long-awaited set of proposed revisions to SEC regulations concerning the disclosure of climate risks and related financial impacts, as well as data on greenhouse gas emissions in certain SEC filings. The recommendation to adopt the new set of rules was not unanimous, with Commissioner Hester Peirce voting against the measure, arguing that the new set of rules is at best unnecessary,… More

Key Takeaways:

• U.S., UK, and EU impose additional sanctions in response to Russia’s continued escalation of conflict in Ukraine
• U.S. imposes sanctions on human rights violators and senior Russian defense officials
• UK sanctions over 370 Russian individuals, including 51 oligarchs and their family members
• EU imposes investment and trade restrictions and sanctions Russian oligarchs, propagandists, state-owned entities, and defense sector entities

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On March 15,… More

This is the tenth and final post in this year’s series examining important trends in white collar law and investigations. Be on the lookout for a roundup of our 2022 White Collar Year in Preview Series shortly.

Last March, we anticipated that the 117th Congress would use the powerful investigative tools at its disposal to drive its legislative agendas. Since then, we have seen congressional inquiries focusing especially intensely on climate change and prescription drug costs.… More

Key Takeaways:

• New Executive Order prohibits certain imports and exports, and authorizes the Department of the Treasury to impose significant restrictions on U.S. investment in Russia
• Additional wave of sanctions targeting Russian “elites” close to President Vladimir Putin
• OFAC guidance clarifies that Russia-related sanctions prohibitions apply to cryptocurrency transactions

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On March 11, 2022, President Biden signed a new Russia-related Executive Order,… More

Key Takeaways:

• The Biden administration announces ban on import of Russian energy commodities and prohibition on new investment in the Russian energy sector
• New General License provides wind-down period until April 22, 2022 for certain energy imports from Russia pursuant to agreements entered into before March 8, 2022
• EU and UK expand their sanctions programs against Russia and Belarus, including additional sanctions on oligarchs
• FinCEN issued an alert to all financial institutions to be vigilant against efforts to evade the expansive sanctions and other restrictions imposed in connection with the invasion of Ukraine

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I.… More

This is the ninth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in SEC enforcement of ESG priorities. Up next: Looking at the Landscape of Congressional Investigations in 2022.

In 2021, various federal entities took steps toward establishing and exerting their enforcement authority against businesses and individuals transacting in cryptocurrency (or “crypto”),… More

This is the eighth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in False Claims Act enforcement. Up next: trends in Federal Cryptocurrency Enforcement in 2022.

Key Takeaways

• Sensitive to criticism of regulation through litigation, the SEC’s Enforcement Division has not pursued cases dealing with cutting edge ESG issues before the SEC decides what,…

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Key Takeaways:

• U.S. imposes additional sanctions on Russian elites, along with their family members, companies, and personal vehicles
• Actions targeting the defense sector and Russian government-affiliated media outlets signal the expansion of U.S. sanctions to new industries
• SWIFT access to be denied to seven Russian banks on March 12, 2022
• New export controls target Belarus and further restrict export of items that use encryption to Russia and Belarus

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I.… More

This is the seventh post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed SEC Enforcement in 2022: A Look Ahead. Up next: ESG and the SEC: What’s Next on the Horizon.

Looking further ahead into 2023, we expect to see several trends in the DOJ’s enforcement of the False Claims Act:

• First,…

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Key Takeaways: 

• New Directive 4 prohibits transactions with Russian Central Bank, National Wealth Fund, and Ministry of Finance
• Full blocking sanctions on Russian Direct Investment Fund and affiliates
• Multi-lateral response to Russia’s invasion continues with unprecedented imposition of sanctions by Switzerland and Monaco

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On February 28, 2022, the U.S. government announced new sanctions on the Central Bank of Russia,… More