2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more
The sanctions world experienced another action-packed year in 2023. Sanctions against Russia dominated the year in terms of the number of designations and new restrictions, and the attacks perpetrated by Hamas in Israel on 7...more
Trade-based money laundering (TBML) describes a set of techniques through which drug traffickers, terrorists and other criminals use the veneer of trade to move illicit funds across borders while disguising the origin and...more
On May 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 14059, against four individuals involved in the fentanyl trade, along with two related...more
2022 was an unprecedented year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). While the sweeping new U.S. sanctions imposed against Russia and Belarus in unparalleled...more
Recent developments in the European Union (EU) as well as political demands indicate that the criminal prosecution of sanctions violations in the EU will be further intensified and possibly even centralized:...more
Jüngere Entwicklungen in der Europäischen Union („EU“) sowie politische Forderungen deuten darauf hin, dass die strafrechtliche Verfolgung von Sanktionsverstößen in der EU weiter intensiviert und gegebenenfalls sogar...more
Since its last enforcement action against Banco Popular in late May, OFAC has been quiet on the enforcement front. Notwithstanding its silence, OFAC has been managing a robust and complex coordinated economic sanctions...more
As 2020 drew to a close, enforcement authorities throughout the United States and the Americas continued to investigate fraud, corruption, and other misconduct across the region. In this newsletter, we highlight some...more
As 2020 drew to a close, enforcement authorities throughout the United States and the Americas continued to investigate fraud, corruption, and other misconduct across the region. Below, we highlight some developments from...more
“Front” Seafood Businesses Allegedly Hid the Proceeds From Smuggled Shark Fins and Marijuana Distribution - Last week, the U.S. Attorney’s Office for the Southern District of Georgia unsealed an indictment returned in July,...more
U.S. Developments - Veritaseum Founder Provides Response to Asset Freeze Order - Responding to an emergency application filed by the Securities and Exchange Commission, Judge LaShann DeArcy Hall of the United States...more
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more
On April 17, 2019, the United States Attorney’s Office for the Southern District of Florida (the “Government”) announced its non-prosecution agreement (available here) entered into with a Miami-based gold refinery, Republic...more
This quarter, companies around the globe prepared to exit Iran-related business in the wake of U.S. sanctions snap-back. Meanwhile, OFAC provided a path to relief to designated Russian entities, extending several deadlines...more
The first six months of the Trump Administration saw several notable developments for US sanctions, with particular implications for Russia and Iran. The Administration also declared a shift in US policy toward Cuba. ...more
The Treasury Department’s Financial Crimes Enforcement Network has been flexing its muscles lately to remind everyone of its important role in money laundering enforcement. Jennifer Shasky, the current Director, a former...more