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Paul Zimmerman

Showing 6 posts by Bradley Henry.

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Quick Resource Guide to Foreign Corrupt Practices Act (FCPA) for Turkish Companies

Lawyers from Michelman & Robinson and Cetinkaya have authored a recently published white paper titled “FCPA for Turkish Companies.” This is a comprehensive resource guide to the Foreign Corrupt Practices Act and its application in Turkey. You can read the white paper here.

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The Anti-Money Laundering Act of 2020: New Rules for Your Business

Early this year, the U.S. Congress enacted the National Defense Authorization Act, which included the Anti-Money Laundering Act of 2020 (AMLA or the Act). With the passage of the dramatic new set of laws came a broad range of fresh anti-money laundering obligations for banks and other financial institutions, certain private investment structures, and even federal regulators.

In the wake of this relatively recent legislation, several questions have arisen, especially with regard to compliance and the Act’s operational impacts. Many of the more significant, top-line issues are addressed here. (Read More)

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The U.S. Has Designated 18 Additional Iranian Banks for Sanctions

The U.S. government has levied additional sanctions on the Iranian financial sector that will put further strain on Tehran’s ability to access the international financial system. The designations are based upon an Executive Order President Trump issued in January 2020 giving the Secretary of State and the Secretary of Treasury the ability to impose sanctions on any part of Iran’s economy. (Read More)

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CFTC Issues Guidance on Corporate Compliance Programs

The mission of the Commodity Futures Trading Commission (CFTC) is crystal clear: “to promote the integrity, resilience, and vibrancy of the U.S. derivatives markets through sound regulation.” And with recent guidance that, as of this writing, will soon be included in the CTFC’s enforcement manual, the agency has taken another step towards achieving its stated objective. (Read More)

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Delaware and U.S. Treasury to Collaborate on Sanctions Enforcement

Nonfinancial companies incorporated in Delaware may be in line for enhanced sanctions enforcement in the wake of an agreement recently entered between state officials and the U.S. Treasury Department.

Earlier this month, the Delaware Department of Justice and the U.S. Department of Treasury’s Office of Foreign Assets Control —which is tasked with enforcing U.S. sanctions—executed a memorandum of understanding that allows officials from Delaware and OFAC to join forces to shut down or otherwise disrupt illicit activities, including those of parties seeking to hide transactions behind anonymous entities. (Read More)

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FinCEN Expands Anti-Money Laundering Regulation and Oversight

The Financial Crimes Enforcement Network (“FinCEN”) has published a final rule requiring all banks not otherwise regulated or overseen by the federal government to establish and implement anti-money laundering programs. In so doing, FinCEN is unleashing relevant sections of the USA PATRIOT Act, removing the anti-money laundering program exemption for banks that lack a federal functional regulator, and extending to those financial institutions—private and other non-federally regulated banks; state-charted, non-depository trust companies; and non-federally insured credit unions—mandatory customer identification programs and beneficial owner requirements. (Read More)