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Maxine Jacobson

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Maxine is a member of the Litigation and Government Enforcement Practice Group and is a member of the Compliance and Investigations, and Dispute Resolution Practice Groups in our Washington, DC office. Maxine’s experience includes working as a summer associate at Baker McKenzie in 2020 where she focused on FCPA matters as well as trade, economic sanctions and US foreign investment restrictions. Maxine has previously interned for the Department of Justice’s National Security Division, Department of Defense’s Office of Military Commissions, and the Treasury Department’s Office of Foreign Assets Control. Prior to law school, Maxine worked for the Center on National Security at Fordham Law where she conducted counter-terrorism research.

Recently, the U.S. Securities and Exchange Commission (“SEC”) Division of Corporation Finance issued a sample letter advising companies on their potential need to disclose direct and indirect impact of Russia’s invasion of Ukraine and the related international response on their operations. Sample letters generally do not create any new legal obligations; instead, they signal the areas of potential scrutiny by the SEC and illustrate the types of risks the SEC may view as material.

In a sign that Congress continues to pursue bipartisan efforts to combat the use of forced labor in supply chains, Senators Josh Hawley and Kirsten Gillibrand have reintroduced the Slave-Free Business Certification Act of 2022. The Act would impose significant new compliance and disclosure requirements for many companies, requiring businesses with annual, worldwide gross receipts exceeding USD 500 million to conduct annual audits of their supply chains to detect any use of forced labor, report findings to the US Government, and face potentially significant fines and penalties for violations.