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Last night, the Obama Administration unveiled additional sanctions measures directed at deterring transactions between non-US persons and Iran, including through additional restrictions on US correspondent banking activity and expanded authority to retaliate...

The U.S. Court of Appeals for the Seventh Circuit has become the first Court of Appeals to address information exchanges in the pre-transaction context. In the long-awaited Omnicare, Inc. v. UnitedHealth Group, Inc., the Seventh Circuit examined, among other topics,...

The Office of the Comptroller of the Currency, Treasury; Board of Governors of the Federal Reserve System; Federal Deposit Insurance Corporation; Office of Thrift Supervision, Treasury; National Credit Union Administration ("NCUA"); U.S. Securities and...

The Commodity Futures Trading Commission (the "CFTC") has proposed rules that would remove the exemptions that many US fund managers and non US fund managers of US funds currently rely on to avoid the need to register as commodity pool operators ("CPOs")...

Earlier this week, the United States Court of Appeals for the Federal Circuit ("CAFC") voided a patent holder's big win at trial (permanent injunction along with its $29 million damage award) after the patent holder surrendered during reexamination...

On October 5, 2011, the US Treasury Department issued a final rule implementing the US correspondent account provision of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 ("CISADA"). The final rule only lightly modifies the...

The Securities and Exchange Commission (the "SEC") issued final rules (the "Final Rules") on June 20, 2012 to implement Section 952 of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank").  Section 952...

The Securities and Exchange Commission (the "SEC") issued a proposed rule (the "Proposed Rule") on March 30, 2011 to implement Section 952 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Act"), which generally...

When investigators are forming their view as to whether a non-US company should be criminally prosecuted for violations of US export controls and economic sanctions, they examine the company's choices at key decision points – how many times did the...

Following the first trial and jury conviction of a corporate defendant under the Foreign Corrupt Practices Act, the Department of Justice has another cudgel to beat back challenges to its aggressive enforcement efforts. Alternatively, companies considering raising...