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Sanctions Investigations

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In keeping with tradition, we are pleased to invite you to our annual Global Year-End Review of Import/Export & Trade Compliance Developments Conference. The conference will provide valuable insights on the latest developments, challenges and opportunities in the ever-changing landscape of international trade. We are holding this conference in a split-hybrid format, with an in-person event in Santa Clara, CA, on November 12 and virtual panels on November 19-21. Please see details below. In-Person Event Join us for a crucial…

As risks and complexities for sanctions investigations have grown, so has the number of regulators and enforcement agencies bringing enforcement actions, and not just in the United States. Enforcement agencies around the world are becoming more active, with a focus on enforcing sanctions and export controls targeting Russia since its February 2022 invasion of Ukraine. There has been a particular uptick in public enforcement of EU sanctions targeting Russia by various EU Member States in…

In the midst of ongoing sanctions investigations and enforcement actions, companies are faced with yet another challenge: interested third-party stakeholders. Companies must decide who to share information with, what levels and types of information to share, how to share information, and how to mitigate the risks of loss of legal privilege, leaks, and triggering disclosure/reporting obligations by others. In this blog post, the Global Sanctions Investigations Group focuses on three critical third party stakeholders –…

As regulations evolve and enforcement intensifies, effective documentation of sanctions investigation results has never been more critical. Proper documentation is crucial not only for maintaining legal privileges and the confidentiality of sensitive information, but also for supporting legal defenses in potential regulatory enforcement in the future. Additionally, companies may have an obligation to disclose investigation results to their external auditors, shareholders, and other stakeholders (e.g., transaction counterparties), underscoring the importance of appropriate documentation to ensure…