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BIS Proposes Revised Penalty Guidelines for Civil Enforcement Cases

USA - January 6 2016 On December 28, 2015, the U.S. Commerce Department's Bureau of Industry and Security ("BIS") published a proposed rule that would amend BIS guidance...

Michael T. Gershberg.


OFAC Issues Cyber-Related Sanctions Regulations

USA - January 4 2016 On December 31, 2015, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") published a final rule to formally create a new...

Michael T. Gershberg.


SEC Proposes Revised Rule on Disclosure of Payments by Resource Extraction Issuers

USA - December 21 2015 On December 11, 2015, the Securities and Exchange Commission (the “SEC”) released a revised proposed rule implementing disclosure...

Michael T. Gershberg, Steven M. Witzel, Joshua Thomas Coleman, Joshua D. Roth, Stuart H. Gelfond.


OFAC announces settlements in significant sanctions enforcement cases

USA - November 13 2015 In the last month, the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC") has announced two significant settlements related to...

Michael T. Gershberg.


D.C. Circuit rules against Conflict Minerals Rule disclosure requirement

USA - August 21 2015 On August 18, 2015, a divided three-judge panel of the U.S. Court of Appeals for the D.C. Circuit confirmed its earlier ruling striking down part of...

Michael T. Gershberg, Mario Mancuso.