News & Analysis as of

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

NY Regulator Releases First Regulatory Framework For Virtual Currency

It happened: Benjamin Lawsky, Superintendent of New York’s Department of Financial Services (DFS) announced the release of the DFS’s much-anticipated proposal for a BitLicense, stating “We have sought to strike an appropriate...more

Red Notice Newsletter - July 2014

Welcome to the July 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, two Noble Corporation executives settle with the U.S. Securities and Exchange...more

Ukraine Crisis Update: US and EU Expand Sanctions, Restrict Certain Energy-Related Exports to Russia

US extends sanctions to three Russian banks, a shipbuilding company and exports of energy sector items to Russia; EU announces similar measures. Additional OFAC Designations - On July 29, 2014, the U.S....more

DOJ Fines Bank Record $9 Billion for OFAC Sanctions Violations

The U.S. Department of Justice (DOJ) recently sent a strong message to international banks with a record penalty of nearly $9 billion on one of the world's largest banks for violating U.S. sanctions against Sudan, Cuba and...more

Sifting Through The Ukraine Economic Sanctions

It is odd how a foreign crisis can have a dramatic impact on the world of ethics and compliance. Foreign policy headaches turn into compliance nightmares when the United States becomes embroiled in foreign events....more

French Bank Sets Aside Over $1 Billion for US Sanctions Violations

French bank BNP Paribas (BNP) recently announced it has set aside $1.1 billion to cover the anticipated cost of violations of US economic sanctions and anti-money laundering rules. The bank's own internal investigation...more

$1.1 Billion and Counting – The New Era of OFAC Enforcement

On February 13, 2014, BNP Paribas ("BNP"), France's largest bank, announced in its fourth quarter results that it will soon be joining the growing community of banking institutions that, within the past five years, have been...more

OFAC Announces Sanctions Settlement With Securities Intermediary

On January 23, the Treasury Department’s OFAC announced that a Luxembourg bank agreed to pay $152 million to resolve potential civil claims that the bank concealed the interest of the Central Bank of Iran (CBI) in certain...more

Two Non-U.S. Banks Agree to Pay Penalties Totaling $160 Million for Violations of U.S. Sanctions Laws Resulting from Omnibus...

Recent enforcement actions brought by the U.S. Government against non-U.S. banks for violations of U.S. sanctions laws demonstrate the need for financial institutions, particularly those that act as custodians or financial...more

"'Know Your Customer': OFAC Raises Due Diligence Expectations of Non-US Banks"

Since 2005, a series of very large non-U.S. banks — including ABN AMRO, Credit Suisse and ING — have paid significant penalties to U.S. authorities for processing funds transfers through the United States related to business...more

Federal, State Authorities Announce Coordinated Economic Sanctions Enforcement Actions Against Foreign Bank

On December 11, the Federal Reserve Board, the Treasury Department’s Office of Foreign Assets and Controls (OFAC), and the New York Department of Financial Services (DFS) announced that a foreign bank agreed to pay $100...more

So, You inherited an unreported offshore account, now what!

There may have been a time when inheriting an unreported offshore financial account was not problematic; but not today. The executor/trustee of the estate of the decedent has fiduciary responsibility to IRS and faces personal...more

Sanctions Round-Up: Second Quarter 2013

In this issue: - The Iran Freedom and Counter-Proliferation Act of 2012 - E.O. 13645, issued June 3, 2013 - Enforcement Against Foreign Sanctions Evaders - Enforcement Against Human Rights...more

New York Announces Agreement To Resolve Alleged International Sanctions Violations

On June 20, New York announced a consent order with the New York branch of a foreign bank to resolve charges that the bank — over a five year period that ended more than five years ago — violated Bank Secrecy Act, Anti-Money...more

The United States Court of Appeals for the Second Circuit Rejects Aiding and Abetting Liability for Civil Damage Claims Under the...

The United States Court of Appeals for the Second Circuit issued an opinion on February 14, 2013, holding that the civil liability provision of the Anti-Terrorism Act of 1990, 18 U.S.C.§ 2333(a) (the “ATA”) does not permit...more

Iran Sanctions Update

The United States continues to impose additional layers of sanctions on Iran. The rate of change and complexity of U.S. sanctions laws present challenges, particularly where these sanctions have extraterritorial effect on the...more

U.S. Law Enforcement Authorities And Regulators Resolve Significant Money Laundering And Sanctions Investigations

On December 11, a major international bank holding company announced agreements with U.S. law enforcement authorities and federal bank regulators to end investigations into alleged inadequate compliance with anti-money...more

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