On the Hunt: Increased Regulation of International Entities

Welcome to the September 2023 edition of our newsletter!  In this issue, we’ll examine heightened scrutiny of deal facilitators as authorities seek to crack down on fraud, especially concerning international clients.

Wars of Attrition: How Foreign Policy Measures Influence Regulatory Scrutiny at Home

More than 18 months into the Russian war against Ukraine, the hunt for assets of Russian “oligarchs” has had a ripple effect across multiple industries.  As part of its task force seeking to sanction billionaires who may be funding, or otherwise benefiting from, Russia’s war effort, the U.S. Justice Department has begun to scrutinize attorneys and others who have worked to help such “oligarchs” set up businesses in recent years.

This extra layer of investigation requires greater effort by those seeking to work with potential targets of international investigations – either those which have begun or could commence in the future.  Does the party your firm is looking to work with have any exposure to assets, either in the U.S. or abroad, that could later be subject to inquiry or seizure because of their connection to a relevant individual or company?  Although investigations and the reasons for them can be very fluid, one constant need is that of fully understanding who you’re looking to do business with, and the risks involved, both present on the surface and likely to emerge in the future.