OFAC Sanctions the Gupta Family for Bribery, Corruption and Misappropriation of South African State Assets

By Kevin McCart, Richard Gibbon, Sassi Riar & Patrick Fenior

November 20, 2019

In an earlier post, here, we examined the Global Magnitsky Human Rights Accountability Act (“GloMag”), which was formally implemented by an Executive Order that declared “serious human rights abuses and corruption globally” as an emergency threat to U.S. interests. The President delegated his authority under GloMag to the Global Targeting Office of the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State to sanction human rights…

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 Richard Gibbon, 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 Richard Gibbon, 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…

The Anticorruption Blog

Hoskins May Limit Extraterritorial Enforcement of U.S. Sanctions

By Jacquelyn Desch & Kevin McCart

September 13, 2018

The Second Circuit’s recent decision in United States v. Hoskins may impact enforcement of U.S. economic sanctions programs. The Hoskins decision precludes the government from charging a foreign national acting abroad with violating the Foreign Corrupt Practices Act (“FCPA”) through theories of conspiracy and accomplice liability. This holding is equally applicable to U.S. sanctions law.…

Kevin McCart

OFAC Sanctions the Gupta Family for Bribery, Corruption and Misappropriation of South African State Assets

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

Hoskins May Limit Extraterritorial Enforcement of U.S. Sanctions

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