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Lessons Learned from Recent OFAC Enforcement Actions

Two recent OFAC enforcement actions highlight real-world challenges that financial institutions and other companies may face in their efforts to implement an effective sanctions compliance program....more

Five Federal Agencies Issue Joint Statement on Approach to Customer Due Diligence

On July 6, five federal agencies − the Board of Governors of the Federal Reserve System (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Financial Crimes Enforcement Network (“FinCEN”), National Credit Union...more

OFAC Settles with Puerto Rico-Based Bank over Apparent Sanctions Compliance Lapse

On May 27, OFAC announced a civil settlement with a Puerto Rico-based bank in connection with apparent violations of the Venezuela Sanctions Regulations. While the settlement amount of $255,938 is a fraction of the...more

New Round of Russia Sanctions

Following reports of alleged atrocities committed by Russian forces in parts of Ukraine, the United States and the European Union have announced significant new economic sanctions aimed at further cutting off Russia from...more

The Biden Budget: Funding Sanctions and AML Initiatives

Increased defense spending and assistance to the Ukrainian government in Kyiv grabbed many of the headlines regarding President Biden’s fiscal year 2023 budget. However, funding requests for key functions within the...more

Russia Sanctions Update: Lux Edition

As the conflict in Ukraine grinds on, sanctions against Russia have continued to tighten. Since we published our Clients & Friends Memo last week, available here, President Biden issued Executive Order (“EO”) 14068 of March...more

In Depth: Listen to Your Regulator on Sanctions and Crypto

It should come as no surprise that the crushing sanctions imposed on Russia in recent weeks will be met with efforts to evade their impact. From Russian firms starved for U.S. dollars to oligarchs starved for that new villa...more

Sanctions March 2022 | Issue No. 166 - Addressing Russia Sanctions Risk

It happened in an instant. Almost overnight Russia, the world’s eleventh-largest economy, was transformed from an important player in global financial markets – both as a destination for investment and a source of capital –...more

Taking Stock: A Survey of the New Russia Sanctions Landscape

Moscow’s invasion of Ukraine has – as promised by US President Joseph R. Biden and other world leaders – provoked “unprecedented” economic sanctions against Russia.  The United States, the United Kingdom, and the European...more

Unwelcome Intrusion: Reckoning with the Impact of Economic Sanctions on Derivatives Transactions

I. A Growing Risk - The United States, along with the United Kingdom and European Union, has increasingly wielded economic sanctions against major commercial actors and financial transactions, sometimes roiling global...more

The Digital Revolution Takes on New Meaning: Among Calls for Heightened U.S. Data Privacy Measures, California is King

California’s ambitious new data privacy law, the California Consumer Privacy Act of 2018 (“CCPA”), will go into effect on January 1, 2020 and promises to bring a new era of digital regulation to America’s shores. ...more

OFAC Publishes Cyber-Related Sanctions Regulations

On December 31, 2015, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued regulations implementing Executive Order 13694 of April 1, 2015, which authorized the imposition of economic sanctions on...more

Supreme Court Rejects SEC's Position Concerning Statute of Limitations in Securities Fraud Actions

On February 27, 2013, the Supreme Court of the United States issued its decision in Gabelli v. SEC, holding that, in an action by the government for civil penalties, the five-year statute of limitations provided by 28 U.S.C....more

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