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Debevoise & Plimpton LLP


US introduces the Sectoral Sanctions Identification List, expands blocking sanctions and export controls

Russia, Ukraine, USA - August 2 2014 On 16 July, under the authority of Executive Order ("EO") 13662, which authorises the imposition of sanctions on companies operating within specific

OFAC revises and clarifies “50 rule”, combines ownership interests of different blocked persons

USA - August 18 2014 On August 13, 2014, the US Treasury Department's Office of Foreign Assets Control (OFAC) revised its published guidance on the so- called "50 Rule"

Anti-corruption enforcement and policies in Brazil: changing times bring a host of developments

Brazil - March 8 2013 Although Brazilian anti-corruption law traces back in time more than 175 years, the ruling by the Brazilian Supreme Court on one of the most

Use of prepaid cards in China

China - December 21 2012 In recent years, the market for commercial prepaid cards has been growing rapidly in China. There are two types of prepaid cards in China: vendor-specific

SEC amends financial responsibility and custody rules

USA - August 9 2013 On July 30, the Securities and Exchange Commission (the "SEC") adopted new rules with respect to broker-dealer financial responsibility and custody

The Year 2015 in Anti-Bribery Enforcement: Are Companies in the Eye of an Enforcement Storm?

Brazil, China, France, Germany, OECD, Russia, United Kingdom, USA - January 26 2016 While one year’s statistics do not, standing alone, make trends, several things about anti-bribery enforcement in 2015 are inescapable. In the United

SEC Proposes New Limits on Registered Funds’ and BDCs’ Use of Derivatives

USA - January 26 2016 On December 11, 2015, the Securities and Exchange Commission (the “SEC”) proposed a new rule 18f-4 (the “Proposed Rule”) under the Investment Company

FDA Publishes Guidance on Postmarket Cybersecurity Risk Management for Medical Device Manufacturers

USA - January 25 2016 As the "Internet of Things" grows, the digital target for malicious actors is growing with it. Not long ago, researchers at the University of South

Supreme Court Rules that Unaccepted Rule 68 Offers of Complete Relief Do Not Moot a Plaintiff’s Case - But Payment of Full Relief Just May

USA - January 25 2016 The Supreme Court ruled last week that defendants may not moot class-action lawsuits by offering complete relief to the individual plaintiffs before

Disclosure Considerations for the 2016 Annual Reporting Season

USA - January 20 2016 For many U.S. public companies, the beginning of a New Year means the beginning of a busy season preparing annual reports and proxy statements. In