SEC termination letter for multinational company
Our client faced no charges at the termination of a case involving sanctions, books and records, and internal controls
Davis Polk secured a termination letter from the SEC terminating without charges a yearslong investigation of a multinational company concerning trade sanction compliance, the company’s books and records, and internal controls. The matter arose in the context of a renewed emphasis by U.S. authorities on compliance with the U.S. sanctions regime. The matter also involved a voluntary-self disclosure to OFAC and a related cautionary letter, indicating that OFAC would not pursue a civil monetary penalty or further enforcement action.
The Davis Polk team included partners Robert A. Cohen, George R. Bason Jr. and Shane Tintle, senior counsel John B. Reynolds III, counsel Nino Stamatovic, Erika A. Kargbo, Will Schisa, Margarita Clarens and Jordan Leigh Smith, and associates Anna Marienko, Chen Chen, Zohaib Chida and Nicole Rose Intrieri. Members of the Davis Polk team are based in the New York and Washington DC offices.