News & Analysis as of

Office of Foreign Assets Control (OFAC) Financial Transactions

The Volkov Law Group

U.S. Sanctions Update as of April 2024

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U.S. Persons prohibited from transactions with anyone on the OFAC SDN List without a license, regardless of country. Includes entities owned in excess of 50-percent by one or more SDNs (33-percent for select Russian...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

WilmerHale

New Multi-Jurisdictional Sanctions Continue to Target Broad Scope of Activities With Russia

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In conjunction with the Group of Seven (G7) leaders meeting in Italy earlier this month, key jurisdictions issued the latest in a series of coordinated economic restrictions on Russia in light of its invasion of Ukraine in...more

Blank Rome LLP

New Russia Sanctions Target IT Services, Enterprise Management Software, and Foreign Financial Transactions

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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”) recently issued a significant new round of sanctions and export...more

Holland & Knight LLP

OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

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Nearly six months after President Joe Biden signed an executive order (EO) authorizing secondary sanctions against Foreign Financial Institutions (FFIs) conducting or facilitating significant transactions with certain...more

BakerHostetler

Current State of U.S. Export Controls in Response to the Russian Federation’s Invasion of Ukraine - May 2024

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In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. ...more

The Volkov Law Group

SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program

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OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws.  If you need to find an example of this long reach, look no...more

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more

Eversheds Sutherland (US) LLP

US sanctions hundreds of targets on two-year anniversary of Russia’s invasion of Ukraine and in response to Aleksei Navalny’s...

Contemporaneous with the European Union’s adoption of its 13th package of Russia sanctions, on February 23, 2024, the United States imposed sanctions against nearly 500 targets in continued response to Russia’s aggression...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - February 2024

BakerHostetler on

In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more

Troutman Pepper

The Cryptocurrency Conundrum: Balancing Innovation with Terrorism Financing Risks

Troutman Pepper on

Cryptocurrency, with its anonymity and decentralization, has revolutionized financial transactions. However, it has also opened doors for illicit activities, such as terrorist financing. Below we explore the role of...more

Vedder Price

Latest Round of Russia Sanctions Targets Foreign Financial Institutions Supporting Russia's Military-Industrial Base

Vedder Price on

On December 22, 2023, President Biden issued Executive Order (E.O.) 14114 further addressing the Russian Federation’s (Russia) continued use of its military-industrial base to support its aggression against Ukraine and to...more

The Volkov Law Group

New Executive Order Expands Treasury’s Authority to Impose ‘Secondary Sanctions’ on Foreign Financial Institutions Involved in...

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On December 22, 2023, President Joseph R. Biden, Jr. issued an executive order—”Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities”—that subjects certain foreign financial institutions that...more

The Volkov Law Group

DOJ Reaches Groundbreaking Criminal Settlement with Cryptocurrency Exchange Binance and CEO Changpeng Zhao (Part I of III)

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On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as...more

Ballard Spahr LLP

Steel Company President with Ties to Russian Oligarch Pleads Guilty to Money Laundering Conspiracy Involving Alleged Sanctions...

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Earlier this month, John Can Unsalan, the president of a steel-making company with ties to Russian oligarchs, pled guilty to one count of conspiracy to commit money laundering, based on financial transactions committed with...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

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The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

Venable LLP

New U.S. Sanctions Target Russia's Industrial Base, Additional Financial Institutions, and Technology Suppliers

Venable LLP on

Since the outset of the Russian aggression in Ukraine, the Biden administration has issued incremental sanctions targeting various sectors of the Russian economy, aimed at curbing Russia's ability to wage war against Ukraine....more

Oberheiden P.C.

OFAC Compliance: Developing and Implementing an Effective Sanctions Compliance Program

Oberheiden P.C. on

Financial institutions and companies that are subject to oversight from the Office of Foreign Assets Control (OFAC) need to prioritize compliance. OFAC has become increasingly active in recent years, and it is devoting...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

Foley Hoag LLP

Russia Sanctions Update - July 27, 2023

Foley Hoag LLP on

On July 20, 2023, the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) designated additional entities in order to further disrupt Russian access to military supplies and deprive the Russian government of...more

The Volkov Law Group

Swedbank Latvia Settles with OFAC for $3.43 Million for Crimea Sanctions Violations

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OFAC continues its enforcement push.  At the same time, OFAC is managing a complex, global set of sanctions against Russia.  DOJ has promised to increase prosecution of global banks for sanctions violations....more

Wilson Sonsini Goodrich & Rosati

Biden Administration Further Expands Export Controls and Sanctions on Russia and Belarus

On May 19, 2023, in conjunction with allies at the 2023 G7 Summit, the Biden administration announced several new actions to counter continued Russian aggression in Ukraine that, among other measures, include a significant...more

Orrick, Herrington & Sutcliffe LLP

OFAC reaches $508 million settlement with British tobacco company on North Korean transactions

On April 25, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $508 million settlement with one of the world’s largest tobacco companies to resolve potential civil liabilities stemming from...more

Akin Gump Strauss Hauer & Feld LLP

Federal Agency Settlements with Wells Fargo Illustrate Sanctions Risks Involving IT Systems

Key Points - On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more

The Volkov Law Group

Wells Fargo Fumbles Sanctions Compliance Demonstrating An Absence of Culture of Compliance (Part II of II)

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Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...more

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