Earlier this year, the Singapore Parliament passed the Criminal Justice Reform Act 2018 (the Criminal Justice Act) introducing, among other things, a formal legislative framework for the Public Prosecutor to enter into deferred prosecution agreements (DPAs) with corporate offenders to resolve misconduct. This change represents a significant shift in Singapore’s approach towards corporate wrongdoing, and
US economic sanctions also affect non-US companies
Over the last few months, US economic sanctions have taken the front pages as the Trump Administration has reinstated certain sanctions aimed at Iran following the United States withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”). While the so-called “snapback” reinstated sanctions provisions increase the risk for non-US companies, recent enforcement actions against non-US companies demonstrate that such companies have always been at risk of violating the US sanctions laws.