- OFAC will only apply new 10-year statute of limitations for a violation that occurred after April 24, 2019; if the violation occurred on or before April 24, 2019, OFAC will only apply the previous 5-year statute of limitations
- OFAC’s record
Latest from Global Investigations & Compliance Review - Page 7
Does the Seventh Amendment Limit State Administrative Adjudication?
At Global Investigations and Compliance Review, we’ve been keeping close tabs on the fallout from the Supreme Court decisions at the end of June. We mentioned in a previous post that the SEC v. Jarkesy opinion may have consequences beyond the
Recent DFSA Enforcement Activity and Future Priorities
In this article, we summarize the trends that have emerged from enforcement actions published between 2022 and the present day by the Dubai Financial Services Authority (the “DFSA”).
Foreign Ownership, Control or Influence (FOCI) Mitigation Specifically for Unclassified Contracts
In May 2024, the US Department of Defense (DoD) published the long-awaited DoD Instruction [1] (FOCI Instruction) expanding the FOCI review process from solely US government contractors that access classified information to all US government contractors performing on certain unclassified
WEBINAR- The 2024 Revolution in Administrative Law: Chevron and Beyond
Join #TeamSPB’s Ben Glassman and Keith Bradley for a timely webinar on the major decisions recently issued by SCOTUS. The panel will cover each of the recent decisions (Loper Bright v. Raimondo, SEC v. Jarkesy, Ohio v. EPA, and Corner
End of the Chevron Era: The Future of Agency Enforcement Shifts to Courts
With its second of two landmark decisions impacting the future of federal agency enforcement, SCOTUS struck down the Chevron decision last week. In a 6-3 decision in Loper Bright Enterprises v. Raimondo, the Court shifted enforcement power away from agencies
SCOTUS Ruling in Jarkesy Foreshadows Big Changes in Federal Enforcement
SPB’s Keith Bradley authored an article for Bloomberg Law covering a recent SCOTUS decision with significant ramifications: SEC v. Jarkesy. We believe that Jarkesy will decidedly shift the landscape of agency adjudication and regulatory enforcement. For the background and possible
The Chevron Reversal and Sanctions Litigation
With the recent SCOTUS decision overturning Chevron, lawyers involved in administrative litigation are considering how the decision will affect their matters. Sanctions litigation is one area which will be impacted. Now, when sanctions designations are challenged in court, the government
Who Determines Materiality of Cybersecurity Incidents in Light of Recent SEC Rule Requiring Disclosure of Cybersecurity Incidents?
In December 2023, the U.S. Securities and Exchange Commission’s (“SEC”) new rule requiring disclosure of material cybersecurity incidents became effective. SPB previously analyzed how the new rule applies to incidents affecting third-party vendors and what companies can do to manage
New 10-Year Statute of Limitations for U.S. Sanctions Violations
On April 24, 2024, President Biden signed into law H.R. 815[1], an emergency supplemental appropriations law, that provides $95.3 billion in military aid to U.S. allies and requires the divestiture of certain social media applications.
While much of