International Trade

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U.S. News – Best Lawyers® Awards Gibson Dunn 132 Top-Tier Rankings

U.S. News – Best Lawyers® awarded Gibson Dunn Tier 1 rankings in 132 practice area categories in its 2019 “Best Law Firms” [PDF] survey. Overall, the firm earned 169 rankings in nine metropolitan areas and nationally.

Firm News | November 1, 2018

Webcast: CFIUS Reform and the Implications for Real Estate Transactions

On August 13, 2018, President Trump signed legislation that will significantly expand the scope of inbound foreign real estate investments subject to review by the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”).

Webcasts | October 18, 2018

OFAC Issues Economic Sanctions Guidance on Digital Currencies

Over the last several months, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has expressed a clear interest in protecting the U.S. financial system from illicit activities in the digital currency space and has posited that transactions involving digital currencies be treated similarly to transactions involving traditional fiat currency.

Client Alert | October 5, 2018

U.S. Authorizes Sanctions for Election Interference

In a recent client alert we foreshadowed the Trump administration taking an aggressive stance on its sanctions policy in the lead-up to the U.S. midterm elections in November.

Client Alert | September 25, 2018

The Trump Trade Tariffs: A Roadmap for Private Equity Executives

Navigating Uncertainty and Volatility for Your Portfolio Companies As the daily headlines attest, trade tariffs – both those recently implemented and those currently pending or contemplated – continue to create a dynamic and challenging business environment, including for portfolio companies of private equity sponsors.

Client Alert | August 21, 2018

CFIUS Reform: Our Analysis

On August 13, 2018, President Trump signed the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (“FY 2019 NDAA”), an omnibus bill to authorize defense spending that includes—among other measures—legislation that will significantly expand the scope of inbound foreign investments subject to review by the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”).

Client Alert | August 14, 2018

The “New” Iran E.O. and the “New” EU Blocking Statute – Navigating the Divide for International Business

On August 6, 2018, President Donald Trump issued a new executive order authorizing the re-imposition of certain Iran-related sanctions.

Client Alert | August 9, 2018

Developments in the Defense of Financial Institutions

To Disclose or Not to Disclose: Analyzing the Consequences of Voluntary Self-Disclosure for Financial Institutions One of the most frequently discussed white collar issues of late has been the benefits of voluntarily self-disclosing to the U.S.

Client Alert | July 12, 2018

2018 Mid-Year FCPA Update

The steady clip of Foreign Corrupt Practices Act ("FCPA") prosecutions set in 2017 has continued apace into the first half of 2018, largely quieting any questions of enforcement of this important statute under the current Administration.

Client Alert | July 9, 2018

Trump Administration Revokes Primary Sanctions Relief Provided by the Iran Nuclear Agreement and Signals Strict Sanctions Enforcement

On June 27, 2018, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") announced it was taking further steps to implement the U.S.

Client Alert | July 2, 2018

Acting Associate AG Panuccio Highlights DOJ’s False Claims Act Enforcement Reform Efforts

On June 14, 2018, Acting Associate Attorney General Jesse Panuccio gave remarks highlighting recent enforcement activity and policy initiatives by the Department of Justice ("DOJ").

Client Alert | June 20, 2018

Revisions to the FFIEC BSA/AML Manual to Include the New CDD Regulation

On May 11, 2018, the federal bank regulators and the Financial Crimes Enforcement Network ("FinCEN") published two new chapters of the Federal Financial Institution Examination Council Bank Secrecy Act/Anti-Money Laundering Examination Manual ("BSA/AML Manual") to reflect changes made by FinCEN to the CDD regulation.

Client Alert | June 14, 2018

President Trump Issues Additional Sanctions Further Targeting PdVSA and the Government of Venezuela

On May 21, 2018, in response to the reelection of Venezuelan President Nicolás Maduro, President Donald J. Trump imposed additional sanctions against the Government of Venezuela.

Client Alert | May 31, 2018

Update on Proposed Changes to the CFIUS Review Process

After six months of wrangling over the fate of a proposal to modernize the process by which the Committee on Foreign Investment in the United States ("CFIUS" or the "Committee") reviews foreign investment in the United States, the U.S.

Client Alert | May 30, 2018

The EU Responds to the U.S. Withdrawal from the Iran Deal

A look at the European reaction to President Donald Trump's decision to re-impose certain sanctions on Iran after exiting the Iran nuclear deal, or Joint Comprehensive Plan of Action.

Client Alert | May 21, 2018

The Trump Administration Pulls the Plug on the Iran Nuclear Agreement

On May 8, 2018, President Donald Trump announced his decision to abandon the 2015 Iran nuclear deal—the Joint Comprehensive Plan of Action (the "JCPOA")—and re-impose U.S.

Client Alert | May 9, 2018

Webcast: Anti-Money Laundering and Sanctions Enforcement and Compliance in 2018 and Beyond

Gibson Dunn partners provide an overview of significant trends and key issues in Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) and sanctions enforcement and compliance.

Webcasts | May 3, 2018

FinCEN Issues FAQs on Customer Due Diligence Regulation

On April 3, 2018, FinCEN issued its long-awaited Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions, FIN-2018-G001.

Client Alert | April 23, 2018

Trump Administration Imposes Unprecedented Russia Sanctions

On April 6, 2018, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") significantly enhanced the impact of sanctions against Russia by blacklisting almost 40 Russian oligarchs, officials, and their affiliated companies pursuant to Obama-era sanctions, as modified by the Countering America's Adversaries Through Sanctions Act ("CAATSA") of 2017.

Client Alert | April 12, 2018

United States Implements Increased Tariffs on Steel and Aluminum Imports: Exclusion Relief Possible

Effective this morning, the United States implemented the increased tariffs on steel and aluminum imports that President Trump announced on March 8, 2018 in Presidential Proclamations implementing findings issued by the Commerce Department under Section 232 of the Trade Expansion Act of 1962, which allows the President to order a national security – focused investigation on the impacts of specified imports and, based upon the findings of the investigation, to impose tariffs without Congressional approval.

Client Alert | March 23, 2018

Webcast: U.S. Economic and Trade Sanctions Against Venezuela – the Outlook for 2018

This 90-minute complimentary webinar will provide a deep dive into the U.S. economic and trade sanctions against Venezuela, including a review of the most recent developments and a forecast of what may be in store for 2018.

Publications | March 13, 2018

2017 Year-End Sanctions Update

A year ago this week, we assessed that the newly-minted Trump administration could follow through on the President's campaign promises and alter several sanctions programs administered by the U.S.

Client Alert | February 5, 2018

U.S. and International Policy Convergence Brings Supply Chain Diligence on Labor Trafficking to the Fore

During the Obama Administration, a number of legal and regulatory developments placed a new premium on the importance of ensuring that supply chains did not include items produced with forced labor or otherwise involve human trafficking.

Client Alert | November 30, 2017

Trump Administration Implements Congressionally Mandated Russia Sanctions – Significant Presidential Discretion Remains

Over the past few weeks the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC") and the U.S. State Department have issued their first round of guidance documents concerning how the Trump Administration will implement the "Countering America's Adversaries Through Sanctions Act" (H.R.

Client Alert | November 21, 2017

Cuba Sanctions: The Trump Administration Takes Steps to Implement Rollback of Obama Era Sanctions Relief

On November 8, 2017, the Treasury Department's Office of Foreign Assets Control ("OFAC"), the Commerce Department's Bureau of Industry and Security ("BIS"), and the State Department released amendments to the Cuban Assets Control Regulations ("CACR") and Export Administration regulations ("EAR"), effective November 9, 2017, implementing President Trump's June 16, 2017 National Security Presidential Memorandum ("NSPM"), "Strengthening the Policy of the United States Towards Cuba." Additionally, while certain transactions with Cuban parties by U.S.

Client Alert | November 16, 2017

Proposed Changes to the CFIUS Review Process

On November 8, 2017, a bipartisan group of lawmakers introduced a long-awaited bill that could significantly alter the process by which the Committee on Foreign Investment in the United States ("CFIUS" or the "Committee") reviews foreign investment in the United States.

Client Alert | November 10, 2017

Webcast: IPO and Public Company Readiness: Regulatory Compliance Issues

​Public companies face unique challenges as they confront and seek to manage OFAC, AML and FCPA compliance risk. Disclosure obligations and market reactions can intensify the pressures arising from alleged or actual violations of these laws.

Webcasts | November 1, 2017

Trump Decertifies the Iran Deal, Creating Both New Uncertainties and Potentially Unexpected Clarity

On Friday, October 13, 2017, President Trump announced a significant change in U.S. policy towards Iran by declaring his intention to refuse to certify to Congress that the 2015 Iran nuclear deal was in the national security interests of the United States.

Client Alert | October 16, 2017

In Latest Salvo, the Trump Administration Pressures Non-U.S. Companies and Persons to Cut Financial and Business Ties with North Korea

On September 20, 2017, the Trump Administration issued a new Executive Order No. 13810, imposing additional sanctions on the Democratic People's Republic of Korea ("DPRK" or "North Korea"), with dramatic implications for foreign persons involved in North Korean trade.

Client Alert | September 26, 2017

Trump Administration Rescinds Deferred Action for Childhood Arrivals (DACA) Program

On September 5, 2017, the Trump Administration announced the termination of the Deferred Action for Childhood Arrivals program ("DACA").  Attorney General Jeff Sessions announced the Administration's decision in remarks delivered on Tuesday morning.  Acting Secretary of Homeland Security Elaine Duke subsequently issued a memorandum formally rescinding the program, after which the White House issued a separate statement explaining President Trump's decision.

Client Alert | September 5, 2017

President Trump Issues New Sanctions Targeting Certain Activities of PdVSA and the Government of Venezuela

Continuing an active month of increased sanctions pressure on Venezuela, on August 24, 2017, President Donald J. Trump issued an executive order imposing a unique set of sanctions targeting transactions involving debt and equity of the Venezuelan government, including Venezuela's state-owned oil company Petroleos de Venezuela, S.A.

Client Alert | September 1, 2017

Congress Seeks to Force (and Tie) President’s Hand on Sanctions Through Passage of Significant New Law Codifying and Expanding U.S. Sanctions on Russia, North Korea, and Iran

Last month, we wrote to you about a "Blockbuster Week in U.S. Sanctions" during which the Senate overwhelmingly approved of a bill that would expand sanctions imposed against Iran and Russia.

Client Alert | July 28, 2017

Update on Immigration Executive Order

Gibson Dunn previously issued several client alerts regarding President Trump's January 27, 2017 and March 6, 2017 Executive Orders restricting entry into the United States for individuals from certain nations and making other immigration-related policy changes.

Client Alert | June 29, 2017

A Blockbuster Week in U.S. Sanctions

In the aftermath of the 2016 U.S. presidential election, many of you asked us how U.S. sanctions would change under the Trump Administration.  Pointing to President Trump's extensive criticism of former President Barack Obama's foreign policy, we predicted significant developments with the Iran and Cuba sanctions programs, and noted that Congress might make its own attempts to force the President's hand with respect to sanctions on the Russian Federation.  These predictions have borne out.  In the space of one week, the U.S.

Client Alert | June 19, 2017

Economic Sanctions Developments in the Early Trump Administration

As we pass the four-month mark of the Trump Administration, uncertainty remains regarding how the new administration will implement its international trade agenda.  In light of President Trump's strong campaign criticisms of President Obama's trade policies, we continue to vigilantly monitor all developments surrounding the new administration's economic sanctions policies.  Despite strong rhetoric to the contrary, early developments within the U.S.

Client Alert | June 12, 2017

Competing Interests Weigh Against Broad Import Controls on Steel Imports After Section 232 Public Hearing

On May 24, 2017, representatives of steel companies, manufactures, trade associations, several sovereign countries, and the U.S.

Client Alert | June 9, 2017

Iran Sanctions Update – Status Quo So Far, Uncertainty Remains

U.S. presidential candidate Donald J. Trump's oft-repeated criticism of President Obama's Iran diplomacy and the resulting nuclear deal, the Joint Comprehensive Plan of Action ("JCPOA"), led many observers to conclude that President Trump would move quickly to dismantle the agreement and the significant sanctions relief that came with it.

Client Alert | May 23, 2017

Court Orders Block Implementation of New Immigration Executive Order

Gibson Dunn previously issued several client alerts regarding President Trump's January 27, 2017 and March 6, 2017 Executive Orders restricting entry into the United States for individuals from certain nations and making other immigration-related policy changes.

Client Alert | March 16, 2017

Analysis of March 6, 2017 Executive Order on Immigration

Gibson Dunn previously issued several client alerts regarding President Trump's January 27, 2017, Executive Order restricting entry into the United States for individuals from certain nations and making other immigration-related policy changes.

Client Alert | March 7, 2017

Recent Developments in Counterfeiting

​Washington, D.C. partner Howard Hogan is the author of "Recent Developments in Counterfeiting," published by The Luxury Law Alliance on February 24, 2017.

Article | February 24, 2017

Over Reliance on Sanctions Will Not Help Anyone’s Cause

​Washington, D.C. partner Adam Smith is the author of "Over Reliance on Sanctions Will Not Help Anyone's Cause," [PDF] published by Gulf News on February 21, 2017.

Article | February 21, 2017

Ninth Circuit Court of Appeals Issues Opinion Upholding Nationwide TRO of January 27 Immigration-Related Executive Order

On Monday, January 30, 2017, Gibson Dunn issued a client alert regarding President Trump's January 27 Executive Order restricting entry into the United States for individuals from certain nations, and making other immigration-related policy changes.

Client Alert | February 10, 2017

Webcast: Tectonic Shifts in the Landscape of Economic Sanctions: Will the Pace of Change in 2016 Continue?

​This briefing highlights recent developments and emerging issues with respect to economic and trade sanctions. Topics discussed include: A Detailed Look at the Iran Nuclear Deal:

Webcasts | February 8, 2017

2016 Year-End Sanctions Update

2016 was a pivotal year in global sanctions implementation, relaxation and enforcement. Against a backdrop of rising nationalism, the international community rallied behind the Joint Comprehensive Plan of Action ("JCPOA"), a deal to ease sanctions on Iran in exchange for limitations on the country’s nuclear program.

Client Alert | February 6, 2017

New Sanctions Against Iran

Less than 48 hours after President Donald J.

Client Alert | February 3, 2017

Recent Developments Regarding Executive Order on Immigration

On Monday, January 30, 2017, Gibson Dunn issued a client alert regarding President Trump's January 27 Executive Order restricting entry into the United States for individuals from certain nations and making other immigration-related policy changes.

Client Alert | February 1, 2017

President Trump Issues Executive Order on Immigration

On January 27, 2017, President Trump issued an Executive Order entitled "Protecting the Nation from Foreign Terrorist Entry into the United States."

Client Alert | January 30, 2017

2016 Year-End United Kingdom White Collar Crime Update

The year 2016 has been another of continuing developments in the UK's white collar sector. These have ranged from the Competition and Markets Authority's largest ever fine, to the UK's second deferred prosecution agreement, to the continuing enforcement efforts of the Serious Fraud Office ("SFO"), National Crime Agency ("NCA") and the Financial Conduct Authority ("FCA"), as well as of a myriad range of other enforcement bodies.

Client Alert | January 11, 2017

President Obama Announces New Russian Sanctions in Response to Election-Related Hacking

On December 29, 2016, in response to Russia's alleged efforts to influence the 2016 U.S. Presidential election through cyber operations, President Obama issued an Executive Order "Taking Additional Steps to Address the National Emergency with Respect to Significant Malicious Cyber-Enabled Activities." Through this Executive Order ("E.O."), the Obama administration imposed sanctions on Russia's two leading intelligence services – the GRU and the FSB – as well as four top officers of the GRU and three companies that provided materials support to GRU's cyber operations.

Client Alert | December 30, 2016

Trade Under Trump: How the New Administration Will Impact U.S. Economic Sanctions and Export Controls

Just over a week has passed since the results of the 2016 U.S. Presidential Election were announced.  As President-elect Donald J.

Client Alert | November 18, 2016

Cuba Sanctions Update – OFAC and BIS Announce Further Amendments to Cuba Sanctions Regulations

On October 14, 2016, the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury and the Bureau of Industry and Security ("BIS") of the U.S.

Client Alert | November 4, 2016

Legal Implications of Expanded Use of Blockchain Technology

​Washington, D.C. partner Judith Lee and counsel Jeffrey Steiner are the authors of "Legal Implications of Expanded Use of Blockchain Technology" [PDF] published in the November 2016 issue of Financier Worldwide.

Article | November 1, 2016

DOJ’s New Guidance Urges Exporters to Self-Disclose Potential Export and Sanctions Violations

On October 2, 2016, the DOJ's National Security Division issued a memorandum entitled "Guidance Regarding Voluntary Self-Disclosures, Cooperation, and Remediation in Export Control and Sanctions Investigations Involving Business Organizations" (the "Guidance").  The Guidance specifies the DOJ's expectations for self-disclosure, cooperation, and remediation for companies seeking maximum mitigation credit in prosecutions for violations of the export-control and sanctions laws under the Arms Export Control Act ("AECA") and the International Emergency Economic Powers Act ("IEEPA").  As a way of background, the AECA is administered by the U.S.

Client Alert | October 28, 2016

Iran Sanctions Update – OFAC Issues Guidance Relating to Compliance and the Scope of Due Diligence for Non-U.S. Persons Engaging in Iran Transactions

On October 7, 2016, the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury issued additional guidance for non-U.S. persons engaging in transactions with Iranian counterparties pursuant to sanctions relief granted on "Implementation Day," January 16, 2016, under the Joint Comprehensive Plan of Action ("JCPOA"), the Iran nuclear deal finalized in July 2015.

Client Alert | October 24, 2016

United States Lifts Burma (Myanmar) Sanctions in Response to Ongoing Democratic Reforms

On October 7, 2016, the Obama Administration announced the lifting of almost all remaining sanctions against Myanmar.  The unwinding of sanctions comes on the heels of Aung San Suu Kyi's visit to the White House on September 14, 2016.  This comprehensive unwinding of sanctions concludes a gradual relief process that first began in 2012.  Most recently, on May 17, 2016, the Administration announced further easing of sanctions on Myanmar in response to Myanmar's historic November 2015 elections in which the National League for Democracy (NLD) – the long-time opposition party led by Aung San Suu Kyi – won an overwhelming majority of seats in the national legislature.

Client Alert | October 10, 2016

2016 Mid-Year United Kingdom White Collar Crime Update

This alert follows on from our inaugural 2015 Year End UK White Collar Crime Update. The continuing pace of development, enforcement and change has encouraged us to produce this update on a bi-annual basis.

Client Alert | September 22, 2016

FinCEN Expands Temporary Reporting Requirements on Title Insurance Companies for All Cash Luxury Real Estate Transactions to Six Major U.S. Areas

On July 27, 2016, the U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN) announced an expansion of the Geographic Targeting Orders (GTOs) targeting alleged money laundering risk in the real estate sector.

Client Alert | August 1, 2016

Key Issues for US Firms to Know about UK Decision to Brexit

​London partner A. Stephen Gillespie is the author of "Key Issues for US Firms to Know about UK Decision to Brexit" [PDF] published on July 6, 2016 by Daily Journal.

Article | July 6, 2016

One Small Step or One Giant Leap? FAA Releases Final Rules on Commercial Drone Use in the United States

After more than a year of considering public comments on its February 23, 2015 proposed rules regulating the commercial use of small (weighing less than 55 pounds) unmanned aircraft systems ("UAS" or "drones"), the United States Federal Aviation Administration ("FAA") on June 22, 2016 issued its final rule, bringing the use of drones one step closer to mainstream commercial integration.While the personal and commercial use of drones has mushroomed in recent years, a practical regulatory framework has lagged behind the technological innovation and economic demand driving the boom.  Proponents of the commercial use of drones have argued that this regulatory lag was stifling the growth of a market that is estimated to generate over $80 billion in t

Client Alert | June 27, 2016

OFAC Issues Additional Guidance on the Scope of Iran Sanctions Easement under JCPOA – Emphasizing the Limited Nature of the Present Relief

On June 8, 2016, the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury further clarified the scope of sanctions relief granted on "Implementation Day" (January 16, 2016) under the Joint Comprehensive Plan of Action ("JCPOA"), the landmark Iran nuclear deal that was finalized in July 2015.  Through publication of several new Frequently Asked Questions ("FAQs"), OFAC offered additional guidance on the application of General License H ("GL H"), which authorizes foreign entities owned or controlled by U.S.

Client Alert | June 16, 2016

Indonesia Update: New Negative Investment List

What is the Negative Investment List? The "Negative Investment List" or "DNI" is a regulation issued under Indonesian law which sets out a list of industry sectors in Indonesia for which foreign investment is either prohibited, permitted or conditionally permitted.

Client Alert | June 6, 2016

Covered Investment

​London partners Cyrus Benson, Penny Madden and associate Ceyda Knoebel are the authors of chapter 1 of The Investment Treaty Arbitration Review, "Covered Investment" [PDF] published in 2016 by Law Business Research.

Article | June 1, 2016

The Directorate of Defense Trade Controls Changes Policy on Exports of Munitions to Vietnam Based on President Obama’s Announcement of Full Lifting of the Vietnam Arms Embargo

On May 23, 2016, President Obama announced a full lifting of the ban on weapons sales to Vietnam during his official visit to the country. Following the President's announcement, the United States Department of State, Directorate of Defense Trade Controls ("DDTC") stated that, effective immediately, and pursuant to a decision made by the Secretary of State, the Department of State's policy prohibiting the sale or transfer of lethal weapons to Vietnam has been terminated.

Client Alert | May 26, 2016

United States Eases Myanmar (Burma) Sanctions in the Wake of Historic Democratic Reform

On May 17, 2016, the Obama Administration announced a continuation of its easing of sanctions on Myanmar. Since the first round of relief was issued in 2013, the United States has consistently held that more relief was possible if Myanmar continued on its path towards democratization.

Client Alert | May 20, 2016

United States Issues Regulations Authorizing Secondary Sanctions Against Non-U.S. Financial Institutions That Support Hizballah

Under U.S. sanctions regulations, U.S. persons have been prohibited from dealing with a number of individuals and entities with connections to the Hizballah organization, by way of designation to the Specially Designated Nationals ("SDN") and Blocked Persons List maintained by the U.S.

Client Alert | April 19, 2016

Webcast: Global Sanctions Update

​This 90 minute briefing provides an update on the extraordinary events of the last year with respect to economic and trade sanctions. The briefing will cover sanctions in the European Union and United Kingdom as well as United States sanctions, and will include particular emphasis on recent developments and emerging issues that affect in-house counsel, compliance personnel, directors and senior executives.

Webcasts | March 24, 2016

United States Restricts Visa Waiver Travel

On January 21, 2016, the U.S. Departments of State and Homeland Security implemented significant changes to the Visa Waiver Program ("VWP") that can severely impede the ability of executives and employees of foreign companies to visit the United States.

Client Alert | February 4, 2016

2015 Year-End Sanctions Update

THE UNITED STATESI.    Major Program Developments            A.    Iran                         1.    Joint Comprehensive Plan of Action (JCPOA)                                    a.    Negotiation and Signing of JCPOA--July 14, 2015On July 14, 2015, the E3/EU+3 (China, France, Germany, the Russian Federation, the United Kingdom, and the United States) signed the Joint Com

Client Alert | February 2, 2016

Webcast – Challenges in Compliance and Corporate Governance – 2016

​The rise of international enforcement efforts and sanctions, the intensifying impact of cyber breaches, the evolution of shareholder activism, and the growing complexity of regulatory requirements are all examples of the expansive array of challenges facing today's compliance professionals.

Webcasts | January 20, 2016

“Implementation Day” Arrives: Substantial Easing of Iran Sanctions alongside Continued Limitations and Risks

On January 16, 2016, the comprehensive international sanctions restricting dealings with Iran and Iranian entities were substantially eased.  Financial institutions and businesses hoping to access the Iranian market have new, immediate and substantial opportunities to do so; but this potential comes with continued complexities, ambiguities, and risks, particularly for U.S.

Client Alert | January 18, 2016

2015 Year-End Update on Corporate Non-Prosecution Agreements (NPAs) and Deferred Prosecution Agreements (DPAs)

2015 was a blockbuster year in corporate non-prosecution agreements ("NPA") and deferred prosecution agreements ("DPA"), by sheer numbers alone. Skyrocketing to 100, in 2015 the number of agreements more than doubled the numbers in every prior year since 2000, when Gibson Dunn first began tracking NPA and DPA data.

Client Alert | January 5, 2016

2015 Year-End FCPA Update

​As we kick off our second decade of updates on the state of play in international anti-corruption enforcement, the stakes for multinational companies have never been higher.

Client Alert | January 4, 2016

OFAC Issues General License Further Relaxing Burmese Sanctions

​Following the recent historic election in Myanmar in which Daw Aung San Suu Kyi and her National League for Democracy won a landslide victory, the political landscape in the country continues to evolve at a fast pace.

Client Alert | December 10, 2015

Personal Liability for Senior Compliance Officers Under New York’s Proposed Anti-Money Laundering and Anti-Terrorism Regulation

(Updated January 5, 2016)On December 1, 2015, New York Governor Andrew M.

Client Alert | December 7, 2015

Serious Fraud Office v Standard Bank Plc: Deferred Prosecution Agreement

UK SFO enters into its first DPA and unveils its first enforcement of the corporate offence of failure to prevent bribery In a judgment of November 30, 2015 in Serious Fraud Office v Standard Bank Plc: Deferred Prosecution Agreement (Case No: U20150854), the Crown Court has approved the United Kingdom's first deferred prosecution agreement (the "Standard Bank DPA") under the regime for DPAs brought into effect in the UK by section 45 and Schedule 17 of the Crime and Courts Act 2013.

Client Alert | December 3, 2015

Webcast: Blockchain Technology

​This webcast covers the basics of blockchain technology, including the evolution of its uses from digital currencies, such as bitcoin, to other areas.

Webcasts | November 17, 2015

The 2015 Myanmar Elections: Impact on Myanmar Sanctions

Myanmar went to the polls on November 8, 2015 (the "2015 Elections") to elect members of the upper and lower houses of the national legislature and 14 state and regional legislatures.  The 2015 Elections witnessed participation by the National League for Democracy (the "NLD") (headed by Aung San Suu Kyi), which had boycotted the 2010 general elections.  Based on the preliminary results released through November 15, 2015, the NLD has secured an overwhelming majority of the seats of the national legislature (referred to as the Pyidaungsu Hluttaw).  The members of the newly elected national legislature will elect the next President of Myanmar to lead the new Myanmar Government from April 1, 2016.  Given the majority secured by the NLD, the next Pre

Client Alert | November 17, 2015

Webcast: The New Era of Fluid Global Sanctions

​This 90 minute briefing provides an overview and assessment of recent substantial changes in key sanctions regimes and the upcoming divergence of US, EU and UN economic sanctions as Iran sanctions relief is implemented, the EU debates the renewal of sanctions against Russia and the US contemplates unilateral sanctions against cyber criminals and others.

Webcasts | October 21, 2015

“Adoption Day” Marks Next Step for Iran Nuclear Deal

​October 18, 2015 marked Adoption Day, the latest milestone in the implementation of the Joint Comprehensive Plan of Action ("JCPOA") between the E3/EU+3 (China, France, Germany, the Russian Federation, the United Kingdom, and the United States) and the Islamic Republic of Iran to ease sanctions on Iran in exchange for limitations on its nuclear program.

Client Alert | October 19, 2015

The Next Frontier in Sanctions Enforcement

​Washington D.C. of counsel Adam Smith is the author of "The Next Frontier in Sanctions Enforcement" [PDF] published in the October - December issue of  Risk & Compliance Magazine

Article | October 1, 2015

Bilateral and Multilateral Investments Treaties: What All Dealmakers Need to Know

​If you are contemplating entering into investments in foreign markets, early consideration of protections available under bilateral investment treaties (BITs) and multilateral investment treaties (MITs) is crucial.  I.     When should you be considering BITs and MITs?BITs and MITs protection should be considered where your investment involves a heavily regulated industry or agreements directly with a foreign state (or state-owned entity)."Investment" for these purposes, potentially covers a broad range of interests and transactions from mergers and acquisitions, joint ventures, purchases of securities or assets, project financing, concession contracts, greenfield asset development, manufacturing plant construction and, in some cases, can also exte

Client Alert | September 25, 2015

Iran Nuclear Deal Poised to Clear Political Hurdle in the United States

Today, the agreement between the E3/EU+3 (China, France, Germany, the Russian Federation, the United Kingdom, and the United States) with the Islamic Republic of Iran to ease sanctions on the country in exchange for limitations on its nuclear program, the Joint Comprehensive Plan of Action ("JCPOA"), took a major political step closer to being realized and implemented in the United States.

Client Alert | September 2, 2015

2015 Mid-Year FCPA Update: Part 2

​Washington, D.C. partners F. Joseph Warin, John W.F. Chesley and associate Stephanie Connor are authors of "2015 Mid-Year FCPA Update (Part 2)" published on August 31, 2015 by Westlaw Journal's Government Contract.  The article is the second installment of a two-part series providing an overview of the FCPA as well as domestic anti-corruption enforcement, litigation, and policy developments in the first half of 2015

Article | August 31, 2015

2015 Mid-Year FCPA Update: Part 1

​Washington, D.C. partners F. Joseph Warin, John W.F. Chesley and associate Stephanie Connor are authors of "2015 Mid-Year FCPA Update (Part 1)" published on August 17, 2015 by Westlaw Journal's Government Contract.  The article is the first installment of a two-part series providing an overview of the FCPA as well as domestic anti-corruption enforcement, litigation, and policy developments in the first half of 2015.

Article | August 17, 2015

Landmark Nuclear Agreement with Iran Reached

On July 14, 2015, the E3/EU+3 (China, France, Germany, the Russian Federation, the United Kingdom, and the United States) signed a landmark agreement with the Islamic Republic of Iran to ease sanctions on the country in exchange for limitations on its nuclear program.  This agreement was the result of intense negotiations beginning in November 2013.  The Joint Comprehensive Plan of Action ("JCPOA" or "the Agreement") removes many of the nuclear-related economic sanctions imposed by the United States and the European Union in the past decade.  As Iran complies with various provisions of the agreement--including caps on its uranium enrichment capabilities and inspections of its key nuclear facilities to ensure that no prohibited activity is occurring--the E

Client Alert | July 14, 2015

2015 Mid-Year Update on Corporate Non-Prosecution Agreements (NPAs) and Deferred Prosecution Agreements (DPAs)

2015 came in like a lion, bringing with it remarkable policy changes regarding corporate non-prosecution agreements ("NPA") and deferred prosecution agreements ("DPA").

Client Alert | July 8, 2015

2015 Mid-Year FCPA Update

For years, U.S. regulators have been encouraging their foreign counterparts to pick up the mantle of international bribery enforcement and more evenly distribute the balance of prosecutions.  With 2015 potentially shaping up to be a year in which transnational bribery prosecutions by foreign authorities match if not exceed U.S.-initiated actions under the Foreign Corrupt Practices Act ("FCPA"), it appears that their calls have been heeded.  But the shifting balance between domestic and foreign regulators does not portend a lull for U.S.

Client Alert | July 6, 2015

A Dealmaker’s Guide to National Security Implications of Foreign Investment in U.S. Government Contractors

Washington, D.C. partners Joseph West and Judith Lee, New York partner Jose Fernandez, and Washington, D.C. staff attorney Andrea F. Farr are the authors of "A Dealmaker's Guide to National Security Implications of Foreign Investment in U.S.

Article | June 30, 2015

Deadline Extended for All New Filers of the Commerce Department’s 2014 Benchmark Survey of U.S. Direct Investment Abroad (BE-10)

As we reported earlier this month, the Department of Commerce, Bureau of Economic Analysis ("BEA") published a final rule in December 2014 that required certain U.S.

Client Alert | May 29, 2015

Virtual Currency Regulation and Enforcement: Granting of First NY Charter and FinCEN Fine Demonstrate Continued Evolution for Virtual Currency Sector

The last several months have demonstrated the continued growth, volatility and regulation of the virtual currency industry. A number of Wall Street institutions and established technology companies have made sizeable investments in virtual currencies and the underlying blockchain technology, and investors aren't the only ones who continue to be interested in the development of virtual currencies.

Client Alert | May 27, 2015

Guidelines for Reporting Under Commerce Department’s Benchmark Survey of U.S. Direct Investment Abroad (BE-10)

On November 20, 2014, the U.S. Department of Commerce, Bureau of Economic Analysis ("BEA") published a final rule amending the Code of Federal Regulations, 15 C.F.R.

Client Alert | May 8, 2015

US Government Implements Historic Changes to Cuba Sanctions Regime

Washington, D.C. partner and Co-Chair of the firm’s International Trade Practice Group, Judith A. Lee and Washington, D.C. associate Annie Yan are authors of, “US Government Implements Historic Changes to Cuba Sanctions Regime” [PDF] published in Risk & Compliance Magazine's April-June 2015 issue.

Article | April 30, 2015

Cybersecurity Sanctions: A Powerful New Tool

 Gibson Dunn partners Judith Alison Lee, Alexander H. Southwell and Jose W. Fernandez and associates Stephenie Gosnell Handler and Eric B. Lorber are authors of the following article published by Law360.  The team addresses an executive order recently signed by President Obama, "Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities," and the broad mandate it provides for the U.S.

Article | April 2, 2015

Blockchain Technology and Legal Implications of ‘Crypto 2.0’

Washington, D.C. partner Judith Lee, New York partner Arthur S. Long,  Washington D.C. counsel Jeffrey L. Steiner, associate Stephenie Gosnell Handler and Palo Alto associate Zachary Wood are the authors of "Blockchain Technology and Legal Implications of ‘Crypto 2.0’" [PDF] published in the March 31, 2015 issue of BNA’s Banking Report.

Article | March 31, 2015

Webcast: Global Sanctions Update

This 90 minute briefing provides an update on the extraordinary events of the last year with respect to economic and trade sanctions. The briefing will cover sanctions in the European Union and United Kingdom as well as United States sanctions, and will include particular emphasis on recent developments and emerging issues that affect in-house counsel, compliance personnel, directors and senior executives.

Webcasts | March 17, 2015

Webcast: Virtual Currencies

Virtual currencies such as Bitcoin have experienced rapid evolution in recent months. Notwithstanding considerable challenges such as price volatility and association with illicit activities, interest in virtual currencies and their underlying technology has been steadily increasing.

Webcasts | March 10, 2015

Venezuela’s Currency Regulations May Violate Investment Treaty Protections

Earlier this month, Venezuela announced a new free-floating exchange rate mechanism, which had the effect of massively devaluing Venezuela's bolivar currency.

Client Alert | February 25, 2015

U.S. Department of State Releases List of Cuban Goods and Services Now Eligible for Importation

As previously reported in our January 20, 2015 Client Alert, "U.S. Department of the Treasury and Department of Commerce Issue Rules Implementing Changes in U.S.

Client Alert | February 25, 2015