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Any business that does business in or via the USA, including doing business in US Dollars is subject to US sanctions law. The USA frequently punishes foreign businesses which it says has breached its sanctions law. While the media focus is usually on action against UK and EU banks, the simple fact is that successful actions have been brought against, even, individuals buying and selling goods via eBay. So, when the US Treasury says "this is how to design your compliance system," it makes a great deal of sense to pay attention. Yesterday, that's what it said. So pay attention.


The pent-up energy in the US government is being released apace. And, of course, the Inland Revenue Service is required to find the money the government needs and, as the shutdown demonstrated, it really doesn't hold much in reserve. And so, within hours of getting back to work, the IRS has issued a warning notice about something employers must do by.., oh, yes, today.

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“The charges unsealed today are the result of years of investigative work conducted by the FBI and our law enforcement partners,” FBI Director Christopher Wray said announcing the charges "unsealed" by United States Attorneys Offices in the Eastern District of New York and the Western District of Washington. The list reads as if someone decided to find a copy Title 18 of the US Code and throw it at Huawei Technologies Co., Ltd. Sadly, Wray's language is political and intemperate and undermines the credibility of the action from the outset.

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It would be nice if the US Department of Justice wrote its media releases in correct English. In this case, despite what the DoJ says, the defendant did not "attempt to extort a marijuana dispensary," he attempted to extort money from the owners of the dispensary. And you thought the only problems California's relaxed attitude to the retailing of MaryJane was how the operators would bank their money. No, the operators are exposed to bad guys wearing suits just as much as bad guys wearing bling and carrying weapons.

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In the 2017 Tax Reform Bill, two major changes to the corporate tax structure will mean Financial Crime Risk Officers will need to scramble to understand how to handle US corporations and to re-write systems, says Nigel Morris-Cotterill. Christmas holidays are at risk if financial services businesses and advisers are to be ready for the new rules many of which will come into force on 1 January, even if PoTUS Trump has not signed the Bill into law by that date.

US President Trump has been looking for a win: for almost a year, the Senate has frustrated his legislative ambitions. His Bill to make fundamental changes to the USA's income and company tax structure was expected to be the next big failure. Instead, it has sailed through both Houses, but its final signing into law will be delayed due to "a procedural issue," although the result of that is a formality in favour of it being passed. Once in place, it will mean the biggest revision of the US Tax Code for more than 30 years. Some of the changes mean that MLROs etc. overseas will need to revise their policies.

We reproduce below, unedited, the full text of two announcements by US-CERT, the US government cyber security office, relating to the HIDDEN COBRA virus which contains information in addition to that previously published.

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We've been trying to access the website at united.com for several minutes. Aside from a pop up about location, nothing else has responded. But what we do know from other media is that United was grounded by the FAA, apparently at the airline's request, for all domestic flights for a period of two hours. International flights were not affected.

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It is fascinating that the USA is having a panic attack about the spread of Da'esh / ISIS by means of propaganda. It is also ironic, given the cultural imperialism that the USA has applied through the entertainment industry - and continues to do so, shaping thinking in so many ways that even in the UK, we find ourselves dominated not by the USA's sharpest minds but by the excessively puerile.

And yet the parallels of how Da'esh / ISIS and the USA spread their messages, and reinforce them, are striking.

The USA's Securities and Exchange Commission is, understandably, delighted: yesterday, it told a Court that USD230 million held in an offshore account in the name of a fund under investigation as a possible ponzi scheme has been transferred to the SEC pending the conclusion of investigations against Highview Point Partners and the operators of the fund.

As the USA's crisis over the failure of Congress to finalise a Federal budget, the US Federal Courts system is one of those on the front line. What will happen if Congress fails to solve the problem tomorrow (8 April).

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The USA's Securities and Exchange Commission has started proceedings against David M Tamman, a lawyer and partner with Greenberg Traurig LLP of Santa Monica, California, alleging improper professional conduct during an SEC examination.

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Wilson Sonsini Goodrich & Rosati have appointed CHEN Wei Heng as partner in its Shanghai corporate and securities practice and co-head of the China practice.

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International law firm Dechert LLP have announced that Thomas P. Vartanian, David L. Ansell, and Robert H. Ledig have joined the firm as partners in the Washington, D.C. office. All three were previously partners at Fried, Frank, Harris, Shriver & Jacobson LLP, where Vartanian served as chairman of the Financial Institutions Transaction Group.

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The USA lumps all kinds of insolvency proceedings under the single heading of "bankruptcy" and so its headline figures are misleading. But behind the headline figure - that there was a near-30% increase in 2009 as against 2008 - there are some trends that indicate a deep malaise in the US economy - and signs that there's still a long way to go before bad debt has returned to actuarially acceptable levels.

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