DOJ Revises Sanctions and Export Self-Disclosure Policy

By Kevin McCart, Clay Porter, Ben Wood, Thomas Zeno, Elizabeth Weil Shaw & Rebecca Worthington

January 28, 2020

The National Security Division recently revised its policy on cooperation credit in order to align with other components of the U.S. Department of Justice. The changes, which are designed to “reassure companies,” are discussed in our client alert available here.…

The Anticorruption Blog

SEC Expands Jurisdiction to Sanctions Violations

By Coates Lear, Kevin McCart, Clay Porter, Ben Wood & Trevor Garmey

November 18, 2019

The Securities and Exchange Commission (“SEC”) recently penalized a public company for violating U.S. economic sanctions. The violation cited the “books and records” and “internal controls” provisions of Securities Exchange Act of 1934 (the “Exchange Act”). With this unprecedented action, the SEC has put companies on notice that the Department of Justice (the “DOJ”) and the Office of Foreign Assets Control (“OFAC”) are not the only sanctions enforcers in Washington. Background It is well known…

The Anticorruption Blog

United Arab Emirates Financial Centers Enhance Economic Security and Business Viability

By Kevin McCart, Ben Wood & Clay Porter

November 13, 2019

In an earlier post, here, we examined Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organizations, the new Federal AML Law enacted by the United Arab Emirates (“UAE”) to ensure best practice anti-money laundering and counter-terrorist financing measures. In this post, we consider how the UAE’s two financial free zones, established in the Emirates of Dubai and Abu Dhabi, which both possess their own civil…

The Anticorruption Blog

Bipartisan Banking Committee Senators Introduce Anti-Money Laundering Reform Bill

By Ben Wood, Kevin McCart, Clay Porter, Matthew Cutts & Patrick Kirby

October 18, 2019

On September 26, 2019, a bipartisan group of eight Senators introduced the Illicit Cash Act[1], which, among other proposed reforms, would require certain companies to disclose beneficial ownership information to the Financial Crimes Enforcement Network (FinCEN) at incorporation and within 90 days of any change in beneficial ownership. Led by Sen. Mark Warner (D-VA), co-sponsors to the bill include Republican Sens. Tom Cotton (R-AR), Mike Rounds (R-SD), John Kennedy (R-LA), and Jerry Moran…

The Anticorruption Blog

United Arab Emirates Issues New AML Law in Context of FATF Evaluation

By Kevin McCart, Ben Wood & Clay Porter

October 1, 2019

The Financial Action Task Force (FATF), an intergovernmental organization founded 30 years ago to develop and uphold policies to combat money laundering and terrorist financing, is conducting a peer review (or “mutual evaluation”) of the United Arab Emirates (UAE) this year. FATF last assessed the UAE in 2008, and found the country’s systems and frameworks geared to prevent criminal abuse of the financial system to be “satisfactory” at that time. FATF made a number…

Ben Wood

DOJ Revises Sanctions and Export Self-Disclosure Policy

SEC Expands Jurisdiction to Sanctions Violations

United Arab Emirates Financial Centers Enhance Economic Security and Business Viability

Bipartisan Banking Committee Senators Introduce Anti-Money Laundering Reform Bill

United Arab Emirates Issues New AML Law in Context of FATF Evaluation

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