News & Analysis as of

Due Diligence U.S. Treasury Compliance

American Conference Institute (ACI)

Industry Responses to the U.S. Outbound Investment Regulatory Regime

The only thing truly certain about the proposed U.S. outbound investment regulatory regime is that a lot of uncertainty remains. But industry responses garnered during the comment period may, at least partly, foretell the...more

Snell & Wilmer

CFIUS & Export Controls: The Foreign Investment Regulations Putting Buyers, Sellers, and M&A Practitioners at Risk

Snell & Wilmer on

In recent memory, enforcement of the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) regulations has been mostly limited and sporadic. But recently, the U.S. government is reviving and...more

American Conference Institute (ACI)

Compliance measures to address sanctions enforcement: ‘the new FCPA’

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

Vinson & Elkins LLP

OFAC Announces a Civil Settlement Agreement For Multiple Sanctions Violations Related To Digital Currency Transactions

Vinson & Elkins LLP on

On February 18, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a half-million dollar settlement with BitPay, Inc. (“BitPay”), a U.S. company that processes digital currency...more

Morrison & Foerster LLP

Following U.S. Lead, UK Office Of Financial Sanctions Implementation Issues Maritime Guidance

Much of the world’s focus is on the COVID-19 pandemic, and rightfully so, but sanctions regulators also have their gazes fixed on another issue: the maritime industry. On May 14 2020, we saw the U.S. Departments of State and...more

Seyfarth Shaw LLP

Culture of Compliance: M&A Transactions Subject To U.S. Department of Treasury Scrutiny

Seyfarth Shaw LLP on

Seyfarth Synopsis: On May 2, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released explicit guidance outlining its expectations for effective written sanctions compliance programs...more

Dechert LLP

U.S. Government Issues Guidance to Reassure U.S. Banks Involved in Foreign Correspondent Relationships

Dechert LLP on

The U.S. Department of the Treasury, together with other U.S. government agencies responsible for enforcing anti-money laundering (AML) and economic sanctions regulations, released guidance on August 30, 2016 in the form of a...more

Morrison & Foerster LLP

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

Davis Wright Tremaine LLP

The Fourth European Union Anti-Money Laundering Directive and Its Effects on Financial Institutions Operating in the EU

The Fourth European Union Anti-Money Laundering Directive (Fourth AML Directive), approved by the European Parliament on May 20, 2015, went into effect on June 25, 2015, repealing the 2005 Third AML Directive. Given the...more

Orrick - Finance 20/20

Treasury Issues Proposed Rules to Enhance Financial Transparency

On July 30, the Financial Crimes Enforcement Network of the U.S Department of the Treasury proposed rules under the Bank Secrecy Act to clarify and strengthen customer due diligence requirements for banks and other financial...more

K&L Gates LLP

Next Phase of FATCA Guidance Arrives with Proposed Regulations and Announcement of Possible Intergovernmental Approach

K&L Gates LLP on

On February 8, 2012, the US Treasury Department (“US Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited proposed regulations on the Foreign Account Tax Compliance Act (“FATCA”). The proposed regulations...more

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