Office of Foreign Assets Control

News & Analysis as of

New Law Significantly Expands Legal Basis for US Sanctions Against Russia

On 16 December 2014, President Obama announced that he will sign the Ukraine Freedom Support Act of 2014 (hereinafter the “Act”) into law. As discussed in our update dated 12 December 2014, the Act represents a potentially...more

U.S. Government Provides Guidance Regarding Certain Temporary Aviation-Related Iran Sanctions Relief

As previously advised, on January 20, 2014, Iran and the group of nations known as the P5+1 (United States, U.K., France, Russia, China and Germany) implemented a Joint Plan of Action (JPOA) whereby Iran agreed to accept...more

OFAC Clarifies Treatment of Deferred Payments, Oil and Gas “Production,” and Artic Offshore Projects Under Russia Sanctions Regime...

On December 11, 2014, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) released new guidance related to existing U.S. sanctions against Russian entities designated on the Sectoral Sanctions...more

US Clarifies Sanctions Provisions and US Senate Passes a Bill to Codify and Expand Sanctions

As noted in previous updates, the United States and European Union continue to impose sanctions against Ukrainian and Russian individuals and entities as a result of the turmoil in Ukraine. On 11 December 2014, the US Senate...more

FFIEC Releases Revised BSA/AML Examination Manual

On November 26, the Federal Financial Institutions Examination Council (FFIEC) released the revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. ...more

OFAC Publishes Guidance Relating to Provision of Temporary Sanctions Relief (Iran)

On December 9, 2014, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), published in the Federal Register (Vol. 79, No. 236, pp. 73141–73143) previously issued guidance relating to the provision of...more

OFAC Settles with Independent Manufacturer for Alleged Violations of the Cuban Assets Control Regulations

Recently, OFAC settled with a Portland, Oregon based manufacturer for allegedly violating the Cuban Assets Control Regulations, 31 C.F.R. part 515. The manufacturer agreed to pay $2,057,540 for the actions of its subsidiary,...more

Financial Regulators Release 2014 Bank Secrecy Act/Anti-Money Laundering Examination Manual

On December 2, the Federal Financial Institutions Examination Council (FFIEC) released the revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. The revisions clarify supervisory expectations and...more

FinCrimes Update - November 2014 Summary, Volume 1, Issue 9

IN THIS ISSUE: BSA/AML & OFAC | Virtual Currency & Payment Systems | FCPA & Anti-Corruption | Criminal Enforcement. ...more

OFAC Sanctions Compliance Provisions in Agreements

Due to costly settlements secured by U.S. regulatory agencies, banks, insurers, and corporations are increasingly inserting rigorous OFAC sanctions compliance language into their credit agreements, insurance policies, and...more

Red Notice Newsletter - November 2014

Welcome to the November 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, a life sciences company settles multi-country bribery investigations, a...more

Managing Legal and Business Risks Under the Russia/Ukraine Sanctions

On October 9, 2014 a team of US, Russia and UK based Latham & Watkins lawyers hosted “Managing Legal and Business Risks Under the Russia/Ukraine Sanctions: Views from the US, Europe and Moscow,” a webcast focusing on the...more

FinCrimes Update - October 2014 Summary, Volume 1, Issue 8

BSA/AML & OFAC: LESSONS LEARNED FROM ARAB BANK'S U.S. ANTI-TERRORISM ACT VERDICT On September 22, 2014, following a two-month trial, a federal jury in the Eastern District of New York ruled in favor of a group of...more

Red Notice Newsletter - October 2014

Welcome to the October 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. - This month on the anticorruption front, a Texas company agrees to pay more than $5 million to settle allegations...more

Banks and the EB-5 Program: Look Before You Leap

Many Washington banks have been asked to serve either as lender for an EB-5 project or as escrow holder to receive EB-5 customer deposits. While the benefits of serving in such roles, especially for a large real estate...more

Sanctions Round-Up: Third Quarter 2014

In this issue: - The Revised OFAC 50 Percent Rule - U.S. and E.U. Sectoral Sanctions Targeting Russia - Additional U.S. Sanctions Targeting Iran - Sanctions Targeting Ongoing Conflicts in Syria,...more

Sanctions Relating to Russia Imposed by the U.S., EU, Australia and Japan - A Snapshot of Where We Are Now

Since early March 2014, a number of countries have imposed various types of sanctions against Russia and certain persons in Ukraine in connection with events in Ukraine. We have issued a series of updates covering, in...more

Accounts and Accountability: Arab Bank Found Liable for Transactions Under the Anti-Terrorism Act

On September 22, 2014, a Brooklyn jury found Arab Bank, Jordan’s largest lender, guilty of violating the U.S. Anti-Terrorism Act for providing financial services to individuals and entities linked to Hamas. Hamas is currently...more

Test Your Knowledge on OFAC Sanctions

Global sanctions have shot up the scale of high risks to be prioritized by international companies and financial institutions, including real estate, corporate and trust service provider businesses. The battle against...more

OFAC Issues New General License Excepting Turkish Lender from Russian Sanctions

On October 6, 2014, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License No. 3, excepting DenizBank AS, a Turkish lender, from the restrictions on access to new debt or new equity under...more

FinCrimes Update - September 2014 Summary, Volume 1, Issue 7

IN THIS ISSUE: BSA/AML & OFAC | Virtual Currency & Payment Systems | FCPA & Anti-Corruption | Criminal Enforcement. BSA/AML & OFAC: FINCEN OFFERS RED FLAGS GUIDANCE ON HUMAN TRAFFICKING AND...more

OFCCP’s New Scheduling Letter and Expanded Itemized Listing

As many federal contractors know, the Office of Federal Contract Compliance Programs (OFCCP) begins a compliance evaluation (or audit) by sending to the selected contractor a letter scheduling the audit. The listing of...more

Recent Trends in DOJ Investigations Against Major Financial Institutions Involving U.S. Economic Sanctions

With the imposition of billion-dollar fines against large financial institutions, the U.S. Department of Justice ("DOJ") is focusing on banks for not only failing to comply with federal laws, but also for willfully violating...more

Overview of the U.S. and EU Sanctions on Russia

Over the past six months, the United States and the European Union have coordinated efforts through sanctions and trade controls to respond to Russian activity in Crimea and Ukraine. Following a long series of incremental...more

Complicating Sanctions Compliance: OFAC Redefines 50 Percent Rule

Companies are worried more and more about sanctions compliance. As the number and complexity of sanctions grow, depending on the twists and turns of our foreign policy, companies are whipsawed in the area of sanctions...more

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