Financial Institutions May Have Civil And Criminal Exposure For Knowingly Or Unknowingly Assisting Customers Who Support Terrorist Activities

While there have been numerous shifts in government enforcement priorities in the past three months, there does appear to be one area where the status quo has remained the same. This new administration has made it clear that preventing financial institutions from working with terrorist organizations remains a top concern. While the administration has added "new" entities to its lists in the form of drug cartels and other nefarious groups, none of this changes [...]

The Fine Line Between Free Speech And Prosecutable Threats

The distinction between free speech and prosecutable threat has become increasingly significant, with organizations understandably questioning what exactly crosses that line. Last year's fatal shooting of a UnitedHealthcare executive and the marked increase in online threats made against other corporate representatives have brought that distinction to the forefront. For corporate executives and in-house counsel, it is important to understand that threatening communications must be specific, unique, and supported by the proof of the speaker's [...]

Compliance In The Era Of “Total Elimination”: What The Administration’s Cartel Focus Means For Cross-Border Business

The exact contours of the national security enforcement landscape under the second Trump administration are still taking shape, but one thing is clear: drug cartels and their financial networks are an enforcement priority. By promising to exercise the sanctions authorities of the U.S. Departments of State and Treasury, revising the U.S. Department of Justice's (DOJ) charging policies, and reassigning prosecutors, the administration's vow to pursue cartels portend an increase in cartel-related enforcement actions. That [...]
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