The first six months of 2014 have seen significant developments in the enforcement of the Foreign Corrupt Practices Act (FCPA) and the Office of Foreign Assets Control (OFAC) sanctions laws. The Justice Department has shown a renewed commitment to using proactive techniques to investigate potential FCPA violations. A federal appeals court issued an opinion interpreting what it means to be an “instrumentality” under the FCPA. The conflict in Ukraine has caused nuanced sanctions to be imposed on Russia, raising numerous interpretive issues. The Joint Plan of Action has resulted in a partial and highly selective suspension of U.S. sanctions on Iran—for the moment. Record penalties are being paid to multiple regulators for sanctions violations, often under novel legal theories. These developments, and others, have myriad potential consequences on companies and financial institutions transacting business overseas. What steps can companies and financial institutions take to stay compliant with these laws? What trends can be gleaned? What do these developments suggest for the rest of 2014?
This interactive webinar provided insights on the top FCPA and sanctions developments in the first half of 2014.
To view the recording of this program, please click here.
July 23, 2014
12:00 p.m. - 1:15 p.m.