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The US Department of Justice (DOJ) Criminal Division announced the publication of updated Guidance on Evaluating Corporate Compliance Programs (2019 Guidance) on April 30, 2019. As discussed in our 2017 FCPA Mid-Year Review, the original guidance, published on February 8, 2017 (2017 Guidance), essentially set forth a list of 11 topics and over 100 detailed questions that the Fraud Section of the DOJ’s Criminal Division stated it would consider when evaluating the effectiveness of…
Steptoe’s International Trade group has put together a helpful guide to the new NAFTA (the US-Mexico-Canada Agreement (USMCA)). The Agreement must still go through ratification and implementation processes in all three countries before it can enter into force. In the coming weeks, the Trump Administration will submit legislation to Congress to implement the USMCA. Before a vote can be taken in the United States, however, the Administration will first need to resolve concerns and objections…
US government enforcement of the Foreign Corrupt Practices Act (FCPA) remained robust in 2018, and the trend of increasing multi-jurisdictional cooperation and enforcement continued throughout the year. In the United States, the 33 combined individual and corporate FCPA enforcement actions concluded by the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) in 2018 were largely consistent with the average number of enforcement actions brought over the last seven years. The US $2.91…
As we have previously written, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated the Venezuelan state-owned oil company Petróleos de Venezuela, S.A. (PdVSA) as a Specially Designated National (SDN) on January 28, 2019. This action will have a significant impact on US persons and businesses involved in any dealings with PdVSA or its subsidiaries. The designation also applies to any entity owned 50% or more by PdVSA, including companies…
On October 17, 2018, Alan Cohn participated in a panel discussion with Daniel Alter of Murphy & McGonigle and Scott Kimpel of Hunton Andrews Kurthen titled “Initial Coin Offerings: Can Securities Regulators Balance Market Growth and Investor Protection?” at the Washington Legal Foundation. Cohn lay the foundation for an in depth discussion on cryptocurrency and regulators approach to balancing market growth and investor protection. Cohn explained that there are a number of overlapping and interlocking regulatory…
On August 3, 2018, twelve years after its last major update, the International Centre for Settlement of Investment Disputes (ICSID) proposed extensive revisions to its rules. The “comprehensive set of proposed changes to modernize its rules for resolving disputes between foreign investors and states” includes new provisions on transparency, arbitrator disclosure, security for costs, and third-party funding. For more information, please see our advisory.…
Steptoe partner Jason Weinstein and of counsel Alan Cohn have been named to The National Law Journal’s list of Trailblazers in Cryptocurrency, Blockchain and FinTech. The list of 50 lawyers is featured in a special supplement in the September issue of the legal publication. Weinstein and Cohn co-chair Steptoe’s global Blockchain and Cryptocurrency practice and are recognized for their leadership on the legal and regulatory issues surrounding cryptocurrency and blockchain technology. Together, they have represented…