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
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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
The Price Cap on Russian Oil – Part 2: Updated OFAC Guidance
In our previous article on this topic (which you can read here), we analyzed recent enforcement activity by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) related to the maritime transport of Russian-origin crude oil
Webinar: The REPO Act – Political and Legal Impacts for International Businesses
Congress recently passed the Rebuilding Prosperity and Opportunity for Ukrainians (“REPO”) Act, bipartisan legislation authorizing the Administration to seize billions of dollars in Russian sovereign assets to fund Ukraine reconstruction and aid. The legislation raises issues that could have political
The Price Cap on Russian Oil – Part 1: Increased OFAC Enforcement
In June 2022, the Group of Seven (“G7”) countries—Canada, France, Germany, Italy, Japan, the United Kingdom, and the United States—decided to pursue a policy to cap the price of Russian oil. In December 2022, the G7 countries, joined by Australia
Navigating AI Risks: A Guide to Enhancing Corporate Compliance Programs
In today’s rapidly evolving technological landscape, the integration of artificial intelligence (“AI”) into business operations presents unparalleled opportunities for efficiency and innovation. Alongside these advancements, however, come new challenges and risks that must be addressed to ensure regulatory compliance and
Increased Corporate Transparency in the Cayman Islands
The Cayman Islands, a British overseas territory, has long been recognized as one of the world’s leading providers of institutionally focused financial services and a preferred destination for the structuring and domiciling of sophisticated and specialized financial services products, particularly
DOJ Promises Whistleblower Rewards Pilot Program and Adds AI Risk to Its Evaluation of Corporation Compliance Programs
On March 7, 2024, US Deputy Attorney General, Lisa O. Monaco announced the development of a new “DOJ-run whistleblower rewards program” during her speech at the American Bar Association’s 39th National Institute on White Collar Crime.[1] The announcement signals
The UAE Exits FATF’s Grey List
On February 23, 2024, the Financial Action Task Force (“FATF”) removed the United Arab Emirates (“UAE”) from its list of jurisdictions under increased monitoring (the “Grey List”). As noted in our previous article (see here), FATF had intimated at
The SDNY Whistleblower Pilot Program Within the Framework of Corporate Criminal Enforcement
The United States Attorney’s Office for the Southern District of New York recently announced a policy—called the “SDNY Whistleblower Pilot Program”—that seeks to encourage individuals to voluntarily disclose financial crimes in which they themselves participated. First unveiled in January 2024