Category: General

United States and United Kingdom Move to Prohibit Russian Oil and Gas Imports

In a much-anticipated action, President Biden announced a prohibition on all Russian oil and gas imports. The United States relies on Russia oil for approximately 8 percent of its needs. Simultaneously, the United Kingdom announced it will reduce oil and gas imports from Russia over the next nine months.  The UK relies on Russian oil and gas imports for approximately 18 percent of its energy...

DOJ Charges Television Producer for Violating Crimea-Related Sanctions Program

The U.S. Attorney’s Office for the Southern Direct of New York recently announced the indictment of Jack Hanick, a United States citizen, of violating the U.S. sanctions against Russia and false statements in connection with his work for a sanctioned oligarch Konstantin Malofeyev. Hanick is a television producer ad worked with Malofeyev, a Specially Designated National (“SDN”) designated under the Crimea Sanctions Program adopted in...

DOJ Enforcement and Compliance with the New Russian Sanctions

The Department of Justice has announced its plan to aggressively enforce the new Russia Sanctions Program.  In response to the dire humanitarian situation in the Ukraine, DOJ took two significant actions – creation of the KleptoCapture Task Force and a commitment to enforcement of the Russia sanctions and export control.  DOJ’s second statement of intent is significant.  DOJ’s record of criminal enforcement of prior sanctions...

United States Announces Additional Sanctions Against Russia and Belarus

As announced during his State of the Union, President Biden and U.S. Allies and partners, announced additional sanctions against Russia and Belarus.  In recognition of the impact of the sanctions and export controls on the energy industry, the United States and Allies released 60 million barrels of oil from strategic reserves. The new restrictions include: Expansion of BIS Sanctions from Russia to Belarus: The United...

Global Update and Review: Russia Sanctions and Asset Capture Initiatives

The Russia-Ukraine crisis has created a fast-moving compliance nightmare – sanctions and export controls around the globe are changing each day.  Some major companies are pulling out of Russia completely in response to the crisis. Others are trying to keep up with sanction requirements and adjusting specific controls each day.  Whatever approach is taken, trade compliance officers have their hands full. United States On the...

OFAC Issues New Sanctions Against Russia’s Central Bank and Sovereign Wealth Funds

In a significant step designed to increase financial pressure on Russia in response to its invasion of Ukraine, the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) issued new sanctions to prohibited United States persons from engaging the Central Bank of the Russia, the National Wealth Fund of Russia, and the Ministry of Finance.  In effect, the new sanctions freeze all Central Bank assets...

United States and Allies Announce Further Sanctions Against Russia Targeting Access to the SWIFT System 

In a significant step, on Saturday, February 26, 2022, the United States and leaders of the European Commission, France, Germany, Italy, the United Kingdom, and Canada announced additional sanctions against key Russian institutions and banks. The weekend announcement indicated that the specific sanctions will be released in the next few days. The United States and Allies explained that the additional measures are designed to “ensure...

President Biden Announces Broad Coordinated Set of Sanctions and Export Controls Against Russia

The Biden Administration announced a robust set of trade sanctions and export controls against Russia in response to the Russian invasion of Ukraine.  The Treasury Department’s Office of Foreign Asset Control (“OFAC”) and the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued broad sanctions and export controls respectively, designed to impose severe economic costs on Russia.  The United States, along with its Allies,...

Lessons Learned from the KT Corp. SEC FCPA Settlement (Part III of III)

Even though the size of the KT Corp. SEC enforcement action is relatively small, the underlying misconduct provides a number of important lessons learned. Let’s look at some of the most significant lessons learned: C-Suite Misconduct: KT’s slush fund was executed by a High-Level executive at KT Corp. and was funded through inflated bonus payments made to executives.  Each executive returned the over-payment to the...

KT Corp’s Bribery Schemes (Part II of III)

When you look under the hood of FCPA enforcement actions, the schemes employed by corporate actors can be shocking. The “creativity” of bad actors can provide important lessons learned and help future investigators when trying to unearth bribery schemes.  At the root of most schemes is brazen arrogance and rationalization of otherwise improper behavior. South Korea From 2009 to 2017, KT high-level executives maintained slush...