Office of Foreign Assets Control

News & Analysis as of

AML and Sanctions Compliance Issues Facing Digital Currency and Blockchain Companies

The United States Department of Justice convened an unprecedented Summit on Digital Currency and the Blockchain on November 9, 2015. The reported goal of the Summit was to promote a dialogue between the government and...more

Federal Reserve and New York DFS Take Action Against Canadian Bank for Deficiencies Relating to AML Compliance

On November 10, the Federal Reserve and the New York DFS announced an enforcement action against a Canadian bank for alleged deficiencies relating to its BSA/AML compliance program. In order to resolve the allegations, the...more

US expands list of medical items authorized for export or re-export under Iran general license

On November 2, 2015, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) updated and expanded the list of “medical supplies” that can qualify for export or re-export to Iran under the existing...more

Federal Reserve and New York DFS Announce $258 Million Penalty Against Global Bank

On November 4, the Federal Reserve and the New York DFS announced a combined $258 million penalty against a global bank for “violations in connection with transactions on behalf of countries and entities subject to U.S....more

Trade & Manufacturing - November 2015

Little Used House Procedure Saves the Ex-Im Bank - Who would have guessed that congressional supporters of the Export-Import Bank (Ex-Im) would have used a House procedure established over 100 years ago, and not used...more

OFAC Expands List of Medical Supplies Eligible for Export to Iran under General License

On November 2, 2015, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated the List of Medical Supplies eligible for export or reexport to Iran under the general license set forth at Section...more

Regulatory Expansions Provide Enhanced Business Opportunities in Cuba

On September 21, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) published updates to their respective Cuba embargo regulations. These...more

OFAC Authorizes Transactions Involving Certain Belarusian Entities

On October 29, OFAC granted a General License authorizing nine Belarusian entities to make transactions otherwise prohibited by Executive Order 13405, effective October 30. The General License also authorizes transactions...more

Red Notice Newsletter - October 2015

Welcome to the October 2015 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, a Japanese multinational conglomerate settles U.S. Securities and Exchange...more

EU and US Take Actions to Ease Belarus Sanctions

On October 29, 2015, the EU and the United States took separate action to ease certain Belarus-related sanctions. As of October 31, 2015, the EU suspended asset freezes and travel restrictions imposed on 170 persons, as well...more

Is Money Being Laundered Through Your Financial Institution Using Daily Fantasy Sports Sites?

This alert addresses the explosion in popularity of daily fantasy sports (“DFS”) sites and the money-laundering potential that DFS sites may offer to criminals around the world. It then explains potential legal liability...more

Movement Towards Implementation of Iran Nuclear Agreement Brings Limited Easing of Sanctions into Focus

Recent and upcoming milestones fuel expectations of Iran opportunities in 2016. As reported in our Client Alert dated July 16, 2015, the Joint Comprehensive Plan of Action (JCPOA) provides for the eventual termination of...more

Multiple Agencies Take Action Against Paris-Based Investment Bank for Sanctions Violations

On October 20, the DOJ, OFAC, the NYDFS, the Manhattan District Attorney’s Office, and the Federal Reserve simultaneously announced that a Paris-based investment bank would pay a total of more than $787 million to settle...more

OFAC Authorizes Certain Transactions and Activities to Liquidate Honduras-Based Bank

On October 21, following the October 7 designation of a Honduras-based bank as a Specially Designated Narcotics Trafficker, OFAC announced that it granted a General License authorizing certain transactions and activities to...more

OFAC Issues Finding of Violation to a Bank for Violations of Iranian Transactions and Sanctions Regulations

On October 21, OFAC issued a Finding of Violation to a Chicago-based bank as the successor of a bank that processed six funds transfers totaling approximately $67,000. According to OFAC, the predecessor bank, between February...more

Cuba Libre?

Cuba banned all private enterprise and foreign investment following Fidel Castro's 1959 revolution. For more than 50 years, the U.S. has imposed an almost total embargo on all trade with the largest Caribbean island nation. ...more

Iran Sanctions: Treasury and White House Comment on JCPOA Adoption Day

On October 18, the Department of the Treasury released a statement on reaching the formal “Adoption Day” of the Joint Comprehensive Plan of Action (JCPOA), the plan reached between the P5+1, the European Union, and Iran...more

Adoption Day in Iran Sanctions Deal: US and EU Give Clarification, But No Lifting of Sanctions Yet

The United States and European Union took preparatory steps on 18 October 2015 to begin fulfilling their commitments to suspend certain sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”)...more

Adoption Day Marks Start of Preparations for Iran Sanctions Relief

October 18, 2015 marked the starting point for official preparations for the expected lifting of sanctions against Iran under the recently agreed Joint Comprehensive Plan of Action (JCPOA). On this day, termed “Adoption Day,”...more

Iran: Adoption Day of the Joint Comprehensive Plan of Action

On 14 July 2015, the Joint Comprehensive Plan of Action (JCPOA) was agreed between the E3/EU+3 (or the P5+1, comprising the United States, Russia, China, the United Kingdom, France and Germany), together with Iran. This was...more

Important Changes to Byzantine Cuban Assets Control Regulations

For over 50 years, the ability to travel to Cuba and do business or trade with Cuban nationals has been governed by a byzantine set of regulations administered by the Department of Treasury’s Office of Foreign Assets Control...more

US State Department Releases Contingent Waivers of Iran Extraterritorial Sanctions

On October 18, 2015, the day on which the Joint Comprehensive Plan of Action (“JCPOA”) became effective (“Adoption Day”), the U.S. Department of State (“State Department”) issued contingent waivers of certain extraterritorial...more

“Adoption Day” Marks Official Launch of P5 + 1 Nuclear Deal with Iran

The Joint Comprehensive Plan of Action (JCPOA), intended to prevent Iran from acquiring a nuclear weapon and to ensure that Iran’s nuclear program will be directed toward exclusively peaceful purposes, went into effect...more

OFAC Announces Honduras-Based Bank as Specially Designated Narcotics Trafficker

On October 7, OFAC announced the designation of a Honduras-Based bank (the Bank) as a Specially Designated Narcotics Trafficker. According to the Department of the Treasury, this announcement “marks the first time that OFAC...more

AML Trends Signal Changing Times For Regional Banks

Recent activity involving state and federal bank regulators reflects an upswing in enforcement actions against regional and super-regional banks for Bank Secrecy Act/anti-money laundering compliance failures. Bank of Mingo,...more

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