Tag Archives: sanctions

D.C. Circuit Vacates SEC Sanctions, Says Negligent Omissions Are Not ‘Willful’ Under Advisers Act

On April 30, the U.S. Circuit Court of Appeals for the District of Columbia Circuit vacated a Securities and Exchange Commission order imposing sanctions. The court held that an investment advisory firm and its owners did not violate Section 207 of the … Continue reading

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OFAC Strongly Encourages Companies to Develop and Implement an Effective Sanctions Compliance Program

On May 2, 2019 US Department of Treasury’s Office of Foreign Assets Control (OFAC) published “A Framework for OFAC Compliance Commitments” (the Framework), which provides a specific outline of what OFAC considers to be essential elements of an effective sanctions … Continue reading

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Avoid Sanctions When Pushing the Legal Envelope

A court may sanction attorneys for engaging in meritless actions or tactics with the intent to harass or cause unnecessary delay. CCP §128.5. But what is meritless to one person may be a rational extension of the law to another. … Continue reading

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U.S. Announces New Sanctions against Cuba, Venezuela and Nicaragua

By Bruce Zagaris On April 17, 2019, the United States government announced new sanctions against Cuba, Venezuela, and Nicaragua. In a Miami speech, National Security Advisor John Bolton announced the Trump administration is reimposing limits on the amount of money … Continue reading

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U.S. extends economic sanctions on Venezuela to its Central Bank

On April 17, 2019, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it had designated Banco Central de Venezuela (Banco Central), the country’s Central Bank, as subject to U.S. economic sanctions. A current director also was sanctioned; … Continue reading

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