William Sweet, Jr.

William Sweet, Jr.

Skadden, Arps, Slate, Meagher & Flom LLP

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"NYDFS Finalizes Rule to Regulate Transaction Monitoring, Filtering"

Financial institutions operating in New York — including New York state licensed banks, trust companies, private bankers, savings banks, savings and loan associations, branches of foreign banks, check cashers, and money...more

7/26/2016 - Banks Department of Financial Services Final Rules Financial Institutions Financial Transactions Proposed Rules Suspicious Activity Reports Transaction Monitoring

"US Further Eases Burma Sanctions"

In response to Burma’s peaceful and competitive elections in November 2015, on May 18, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) further eased U.S. sanctions against Burma (Myanmar). These...more

5/24/2016 - Burma Economic Sanctions Exports Financial Institutions Foreign Investment General Licenses Myanmar OFAC Popular SDN List State-Owned Enterprises

"FinCEN Finalizes Customer Due Diligence Rule Amid Other Actions to Enhance Financial Transparency"

In the wake of the Panama Papers controversy, the U.S. government has taken major steps this month to promote financial transparency. First, the Financial Crimes Enforcement Network (FinCEN) finalized its proposed rule issued...more

5/17/2016 - Anti-Money Laundering Banks Customer Due Diligence (CDD) Due Diligence Economic Sanctions EU Financial Institutions FinCEN OFAC Ownership Requirements Popular Transparency White Collar Crimes

"UK Establishes New HM Treasury Office to Implement Financial Sanctions"

On March 31, 2016, the U.K. launched the new Office of Financial Sanctions Implementation (OFSI) within HM Treasury. OFSI, which assumes the financial sanctions responsibilities previously carried out by HM Treasury’s Asset...more

4/5/2016 - Compliance Economic Sanctions HM Treasury Law Enforcement Office of Financial Sanctions Implementation (OFSI) Penalties UK

"US Further Eases Sanctions Ahead of President’s Historic Trip to Cuba"

On March 15, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) announced regulatory amendments that further eased U.S....more

3/18/2016 - BIS Cuba Economic Sanctions Export Controls Exports Financial Transactions International Travel OFAC

"OFAC and BIS Ease Cuba Restrictions With New Amendments"

On January 27, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) further eased U.S. sanctions and export control regulations...more

2/5/2016 - Aviation Industry BIS Cuba Cuban Assets Control Regulations (CACR) Economic Sanctions Export Controls OFAC Telecommunications Trade Policy

‘Implementation Day’: Key Aspects of US and EU Implementation of Iran Sanctions Relief

On January 16, 2016, the International Atomic Energy Agency verified that Iran had complied with the nuclear-related technical aspects of the Joint Comprehensive Plan of Action it had to complete before the first phase of...more

1/28/2016 - Banking Sector Economic Sanctions EU Foreign Entities IAEA Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Nuclear Weapons OFAC Oil & Gas SDN List

"US Economic Sanctions: New List-Based Programs"

While economic sanctions against Iran, Russia and Cuba have dominated the headlines over the past year, sanctions remain a dynamic component of U.S. foreign policy on other fronts. In 2015, President Barack Obama issued three...more

1/23/2016 - Burundi Cross-Border Transactions Cuba Cyber Attacks Economic Sanctions Executive Orders Foreign Financial Institutions (FFI) Foreign Policy Human Rights Iran Sanctions Obama Administration Russia Venezuela

"Iran Sanctions Changes Will Impact Foreign Financial Institutions in 2016"

Editor’s note: This article includes news developments through January 18, 2016. The historic agreement that the P5+1 (the United States, the United Kingdom, France, China, Russia and Germany) and the European Union...more

1/23/2016 - Financial Institutions Foreign Financial Institutions (FFI) Implementation Day Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Licensing Rules OFAC P5+1 Nations SDN List

"US Enforcement Authorities Tighten Post-Settlement Scrutiny of Financial Institutions"

Last year, financial institutions continued to settle in record numbers with federal and state criminal and civil authorities in areas including benchmark interest rate manipulation, economic sanctions and anti-money...more

1/22/2016 - Anti-Money Laundering Compliance Department of Financial Services Enforcement Authority Financial Institutions Heightened Scrutiny Interest Rates Self-Reporting Settlements

"Developments in Oversight of Virtual Currency Businesses"

Virtual currency businesses saw increased oversight by U.S. regulators in 2015, and continued interest by federal and state authorities is expected as regulation evolves. Two recent developments in this arena are particularly...more

1/22/2016 - Bitcoin Department of Financial Services Virtual Currency

"Insights Conversations: Update on Shareholder Activism in the US Banking Industry"

Two years ago, the U.S. banking industry was a rare exception to the trend of increased shareholder activism that was prevalent across industries. At the time, Skadden partners Brian Christiansen, David Ingles, Sven Mickisch...more

10/1/2015 - Acquisitions Banking Sector Board of Directors Corporate Management Investors Mergers Shareholder Activism

"OFAC and BIS Further Ease Cuba Restrictions"

On September 21, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) amended their respective Cuba regulations to...more

9/30/2015 - Airlines BIS Cuba Cuban Assets Control Regulations (CACR) Export Administration Regulations Export Controls Financial Institutions Financial Transactions Information Technology Internet Service Providers (ISPs) Licenses OFAC Physical Presence Test Sanctions Telecommunications U.S. Commerce Department Vessels

"A Long Time Coming: FinCEN Proposes AML Program and SAR Requirements for Investment Advisers"

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) that would impose certain anti-money laundering (“AML”) requirements on...more

9/11/2015 - Anti-Money Laundering Bank Secrecy Act BSA/AML Currency Transaction Reports (CTR) FinCEN Investment Adviser Know Your Customers NPRM OCIE SEC Suspicious Activity Reports U.S. Treasury

"President Obama Announces New Cybersecurity Sanctions Regime"

On April 1, 2015, President Barack Obama issued an executive order (the Order) authorizing sanctions against foreign individuals or entities found to be responsible for certain malicious cyberattacks. Under the Order, the...more

4/9/2015 - Barack Obama Blocked Person CFIUS Cyber Attacks Cybersecurity Executive Orders OFAC Sanctions SDN List

"New Reporting Requirements on the Horizon for US Financial Services Providers Doing Business With Non-US Persons"

Following closely on the heels of the reinstated reporting requirements for inbound and outbound direct investment involving U.S. entities, the U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) has announced...more

3/3/2015 - Banking Sector Bureau of Economic Analysis Financial Institutions Foreign Direct Investment Foreign Nationals Reporting Requirements U.S. Commerce Department

"New Provisions Require Structural Change for Foreign Banking Organizations"

The Enhanced Prudential Standards (Regulation YY) of the Board of Governors of the Federal Reserve System represent a significant shift in the U.S. regulation of foreign banking organizations (FBOs). In general, Regulation...more

2/6/2015 - Bank Holding Company Banking Sector Banks Dodd-Frank Federal Reserve Foreign Banks Prudential Standards Regulation YY

"MiFID 2: Reforming the Regulation of EU Securities and Derivatives Markets"

The European Union has begun a wide-ranging and radical reform of its securities and derivatives markets through MiFID 2, which is scheduled to be implemented across the EU by January 3, 2017. Implementation is dependent on a...more

1/28/2015 - Derivatives EU Financial Regulatory Reform MiFID Securities

"Lawmakers and Regulators Continue Focus on Strategies for Resolving SIFIs"

The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 contains two sets of provisions for managing the insolvency of financial institutions. First, the legislation creates an Orderly Liquidation Authority...more

1/28/2015 - Banking Sector Bankruptcy Code Banks Counterparties Debt Restructuring Dodd-Frank FBOs FDIC Federal Reserve Financial Institutions Insolvency ISDA Living Will Orderly Liquidation Authority SIFIs

"OFAC and BIS Implement Changes in Cuba Policy"

Since the 1960s, the United States has maintained an embargo on Cuba that in many respects is the most comprehensive set of economic and trade restrictions on any country. On January 16, 2015, amendments to regulations issued...more

1/21/2015 - Amended Regulation Banking Sector BIS Cuba Embargo Executive Orders Exports Imports Obama Administration OFAC Sanctions Telecommunications Trade Relations Travel Permits

"European Central Bank Publishes Final List of 'Significant Supervised Entities' in Preparation for Banking Union"

On 4 September 2014, the EU’s European Central Bank (ECB) published its final list of significant supervised entities and less significant institutions for the purposes of the Eurozone’s single supervisory mechanism (SSM),...more

9/15/2014 - EU European Central Bank Foreign Banks Single Supervisory Mechanism

"An Update on Economic Sanctions Related to Events in Ukraine"

On April 25, 2014, following a meeting of the G7 in which member countries broadly agreed to take further action against Russia in response to political violence and unrest in Ukraine, U.S. officials imposed sanctions against...more

5/7/2014 - EU OFAC Russia Sanctions Ukraine

"US Government Announces Ban on High-Technology Exports to Russia and Crimea"

On April 28, 2014, as part of its evolving response to the situation in Ukraine, the White House announced new restrictions on exports of “high-technology” items and services to Russia and Crimea. The announcement also...more

5/2/2014 - Exports Russia Sanctions Technology Ukraine

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