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Evolution of UK Enforcement Strategies in OFSI Updated Monetary Penalty Guidance for Financial Sanctions Breaches

Giles Thomson (The Office of Financial Sanctions Implementation (OFSI), Director) wrote in the OFSI blog in February 2021 that “OFSI will continue to robustly but fairly and proportionately use the compliance tools available to [it], including monetary penalties, to effectively enforce financial sanctions in the United Kingdom, ensuring they meet the UK’s strategic objectives and maintaining our reputation as a world leader in this area”.

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Two Recent Decisions Provide Rare Guidance on the FCPA's Reach Over Foreign Nationals

Time to Read: 1 minutes Practices: Anti-Corruption / International Risk, Government Enforcement / White Collar Criminal Defense

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Two recent district court decisions have shed light on the reach and scope of the U.S. Foreign Corrupt Practices Act (FCPA) over foreign nationals: SEC v. Straub and SEC v. Sharef. For companies and individuals operating abroad, these cases provide rare judicial guidance on the reach of the FCPA’s anti-bribery and record-keeping provisions. Together, they reaffirm U.S. regulators’ long-standing position that the FCPA has broad applicability to foreign nationals, while also setting the outer limits of the civil scope of the FCPA.

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