Client Advisory: Asia Pacific Holds Steady as Improvements Offset by Declines in 2019 Corruption Rankings

By Wendy Wysong, Ali Burney, Susan Munro, Richard Battaglia, Hena Schommer, Nicholas Turner & Anthony Pan

February 11, 2020

Click here to read the full Client Advisory by Steptoe. On January 23, 2020, Transparency International published its 2019 Corruption Perceptions Index (CPI), which measures perceptions of public sector corruption in 180 countries. Viewed together with the 2019 TRACE Bribery Risk Matrix, which also includes private sector corruption, the Asia Pacific (APAC) region overall remains generally high risk for bribery and corruption relative to other parts of the globe, with some notable…

International Compliance Blog

Client Advisory: The Asia Pacific Top Ten FCPA Enforcement Actions of 2019

By Susan Munro, Hena Schommer, Nicholas Turner, Wendy Wysong, Ali Burney & Richard Battaglia

February 4, 2020

Click here to read the full Client Advisory by Steptoe. Of the record-breaking USD 2.9 billion in fines imposed by US authorities in 2019 for violations of the Foreign Corrupt Practices Act (FCPA), almost 95% involved Asia Pacific, primarily China and India, but also Indonesia, Vietnam, Thailand, and South Korea. This year, the US Department of Justice and the Securities & Exchange Commission had cases against well-known multinational corporations operating in the region, and…

International Compliance Blog

OFAC Removes Secondary Sanctions on COSCO Division Targeted for Iran Oil Imports

By Ed Krauland, Meredith Rathbone, Peter Jeydel, Nicholas Turner, Wendy Wysong, Ali Burney & Anthony Pan

February 3, 2020

On January 31, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) lifted sanctions on China-based COSCO Shipping Tanker (Dalian) Co., Ltd. (COSCO Dalian), five affiliates, and one individual who were named as Specially Designated Nationals (SDNs) in September 2019 for knowingly engaging in a significant transaction for the transport of oil from Iran. Despite last week’s reprieve, another COSCO subsidiary, COSCO Shipping Tanker (Dalian) Seaman and Ship Management Co., Ltd., as well…

International Compliance Blog

OFAC Hits Companies in Hong Kong, China, and Dubai with Secondary Sanctions for Iran Oil Trading

By Nicholas Turner, Wendy Wysong & Ali Burney

January 24, 2020

On January 23, 2020, the US State Department and the Office of Foreign Assets Control (OFAC) named six companies based in Hong Kong, China, and Dubai as Specially Designated Nationals (SDNs) under Executive Order (EO) 13846 for engaging in transactions involving Iran’s petroleum sector and the National Iranian Oil Company (NIOC). OFAC’s designations target two Hong Kong-based trading companies, Triliance Petrochemical Co. Ltd. (Triliance) and Sage Energy HK Limited; Shanghai-based Peakview Industry Co. Limited; and…

International Compliance Blog

Client Advisory: Department of Justice Encourages Self-Disclosures with Revised Sanctions and Export Controls Enforcement Policy

By Jeff Beatrice, Jillian Norton, Hena Schommer, Wendy Wysong & Ali Burney

January 15, 2020

Click here to read the full Client Advisory by Steptoe. In December 2019, the US Department of Justice (DOJ) announced a revised policy regarding voluntary disclosure of export control and sanctions violations by business organizations (VSD Policy). The VSD Policy encourages business organizations – which now include financial institutions – to self-disclose “all potentially willful violations of the statutes implementing the US government’s primary export control and sanctions regime.” For companies that identify…

International Compliance Blog

UPDATED: OFAC Targets Chinese Firms for Iranian Metals Trade, Designates Iranian Officials, as White House Expands Secondary Sanctions with New Executive Order

By Alexandra Baj, Ed Krauland, Meredith Rathbone, Jack Hayes, Brian Egan, Nicholas Turner, Nicholas Kimbrell, Wendy Wysong & Ali Burney

January 10, 2020

Click here to sign up for email alerts from Steptoe. On January 10, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) named Beijing-based Pamchel Trading Beijing Co. Ltd., its Seychelles-based affiliate, and a Chinese vessel and vessel operator as Specially Designated Nationals (SDNs) pursuant to Executive Order (EO) 13871 of May 8, 2019, for engaging in significant transactions involving Iran’s metals sectors. OFAC also designated 13 Iranian steel and iron …

Wendy Wysong

Client Advisory: Asia Pacific Holds Steady as Improvements Offset by Declines in 2019 Corruption Rankings

Client Advisory: The Asia Pacific Top Ten FCPA Enforcement Actions of 2019

OFAC Removes Secondary Sanctions on COSCO Division Targeted for Iran Oil Imports

OFAC Hits Companies in Hong Kong, China, and Dubai with Secondary Sanctions for Iran Oil Trading

Client Advisory: Department of Justice Encourages Self-Disclosures with Revised Sanctions and Export Controls Enforcement Policy

UPDATED: OFAC Targets Chinese Firms for Iranian Metals Trade, Designates Iranian Officials, as White House Expands Secondary Sanctions with New Executive Order

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