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With CDD and Beneficial Ownership Rule in Effect, FinCEN Continues to Clarify and Refine Rules for Financial Institutions

USA - May 21 2018 Long awaited rules for “Customer Due Diligence Requirements for Financial Institutions” (the CDD Rules) went into effect on May 11, 2018. FinCEN has…

Stephan E. Becker, Moushami P. Joshi

US Announces Withdrawal from JCPOA

USA - May 8 2018 Today, President Trump announced his intention to withdraw the United States from the Joint Comprehensive Plan of Action (JCPOA) and to impose the…

Stephan E. Becker, Nancy Fischer, Matthew R. Rabinowitz, Christopher R. Wall

Treasury Department Designates Russian Oligarchs, Officials, and Entities

USA - April 9 2018 The Treasury Department has placed several prominent Russian individuals and companies on the Specially Designated Nationals and Blocked Persons lists…

Stephan E. Becker, Nancy Fischer, Matthew R. Rabinowitz, Jorge Vera, Christopher R. Wall

U.S. Targets Human Rights Abusers and Corrupt Actors Worldwide - Key Takeaways from the Potent New Sanctions

USA - January 10 2018 On December 20, 2017, President Trump issued Executive Order 13818 (the “E.O.”) implementing provisions of the Global Magnitsky Human Rights…

Stephan E. Becker, Sahar Hafeez, Matthew R. Rabinowitz

Large Whistleblower Award to Non U.S. Person- Lessons for Anti-Corruption Compliance Programs

USA - December 13 2017 On December 5, 2017 the Securities and Exchange Commission (“SEC”) awarded more than $4.1 million to a whistleblower for alerting the SEC to a…

Moushami P. Joshi