John Carlin

Top Justice Department Official on Stepping Up Corporate Enforcement

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I think these events [the Global Investigations Review conference: New York] are an important opportunity for discussion of trends and really this area is one where your work, your advice to clients, changes the way that people behave. And it changes the way that people behave in a way that collectively helps to detect, deter and sanction corporate malfeasance. Ultimately, it benefits the rule of law and allows businesses to thrive. And that is in part through robust compliance and enforcement programmes.

[Conference co-chair F. Joseph Warin] referenced a little bit of returning to government on 20 January as a … Read more

Morrison & Foerster Discusses U.S. Treasury Sanctions on Chinese Military Companies

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On December 28, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued five new frequently asked questions (“FAQs”) that clarify the scope of Executive Order (“E.O.”) 13959, the basis for OFAC’s new Chinese Military Companies sanctions program. These FAQs define key terms and clarify how OFAC will interpret E.O. 13959’s prohibition against U.S. investment in the securities of Communist Chinese Military Companies (“CCMCs”), which goes into effect on January 11, 2021. In general, like previous sanctions programs, the new FAQs show that OFAC will read commonly used terms … Read more