Troutman Pepper Locke’s Securities Investigations and Enforcement team counsels and defends clients through all stages of securities enforcement proceedings. Our attorneys have served in key government agencies and regulatory bodies, and bring their insight to bear in each representation. The team includes a former branch chief of the Division of Enforcement at the SEC, former enforcement lawyers, regulators and government attorneys, assistant United States Attorneys and former assistant attorneys general, as well as in-house counsel for public companies. Our lawyers and practice have been identified as leaders in the field by publications such as the Legal 500, SuperLawyers, Benchmark Litigation, and Chambers USA.

WASHINGTON, D.C. – Troutman Pepper Locke advised ODNB Financial Corporation, the holding company for Old Dominion National Bank, a locally owned community bank serving markets including the Washington, D.C. metro area, in the completion of a private placement of a $25 million 7.25% fixed-to-floating rate subordinated note due 2035 to a subsidiary of EJF Capital, LLC, a locally-based global institutional asset management firm specializing in financials. For more information, see the press release.

Overview

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently announced an $11.5 million settlement of an enforcement action against a U.S.-based private equity and infrastructure investment firm (the firm) for violations of U.S. sanctions in connection with an investment indirectly backed by a sanctioned individual. The action provides important guidance on OFAC’s expectations regarding ownership, control, and indirect involvement by sanctioned persons, as well as the limits of relying on outside counsel when material facts are not fully disclosed. This is the latest in a series of similar enforcement actions by OFAC involving the same sanctioned individual and the complex trust structure he established to conceal his interest in U.S. investment funds, including a similar case in June involving a venture capital firm.

A bank’s positive, cooperative relationship with its banking regulators is particularly important when seeking regulatory approval for significant transactions, including mergers. An effective communications strategy that promotes an open, consistent and prompt flow of information, specific regulatory issues and areas of risk under review is key to maintaining a good relationship before, during and after the application review process.

What are the most significant judicial decisions, regulatory changes, and government actions affecting the financial services industry, and how might they impact your business? The following overview provides summaries of our most recent posts, which include case summaries, key takeaways, and practical insights.

What are the most significant judicial decisions, regulatory changes, and government actions affecting the financial services industry, and how might they impact your business? The following overview provides summaries of our most recent posts, which include case summaries, key takeaways, and practical insights.