Office of Foreign Assets Control Reporting Requirements

News & Analysis as of

NYDFS Finalizes AML/BSA Regulation

The New York Department of Financial Services (DFS) has finalized a new regulation setting rigorous standards for monitoring and filtering programs to monitor transactions for potential anti-money laundering (AML) and Bank...more

FinCEN Issues Customer Due Diligence Rules and Amends AML Program Rules

On May 11, 2016, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a final rules release (the “Release”) containing new rules to strengthen customer due diligence (“CDD”) requirements for...more

U.S. Issues Burma General Licenses

In May, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Burmese Sanction Regulations, and the U.S. Department of State (State) proposed revisions to the Burma Responsible...more

Violation of OFAC Reporting Requirements: “No Harm, No Foul”? No Way!

A recent enforcement action by the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) against MasterCard International Incorporated (“MasterCard”) stands as a reminder of the importance of strictly...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

Update on Significant DOT, FAA and Other Federal Agencies’ Aviation-Related Regulatory Actions - October 2015

This edition of the Cozen O’Connor Aviation Regulatory Update reports on Congress’s six-month extension of FAA’s reauthorization; new U.S. Bilateral Aviation Safety Agreements with the European Union and Canada; the FAA’s...more

The 5 Most Common AML Compliance Program Deficiencies

Anti-money laundering compliance is a very difficult task. The number of risks is exponential. AML compliance officers have an innovative and rich history of compliance techniques and strategies. In the end, AML compliance...more

10Qs and 10Ks Now Required to Include Transactions Subject to Economic Sanctions

Effective February 6, 2013, companies required to file quarterly and annual reports (10Qs and 10Ks) with the Securities and Exchange Commission (SEC) are required to include information about certain of their own and their...more

New Iran Sanctions Enactments Apply to U.S. Companies’ Foreign Affiliates and Subsidiaries, and Require SEC Reporting by Public...

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury enforces comprehensive sanctions that regulate, and largely forbid, most forms of trade and financial transactions by U.S. persons with Iran....more

SEC Reporting for Certain 2012 Iran-Related Transactions

Mandatory requirements cover actions of issuers' foreign subsidiaries and affiliates. On August 10, 2012, section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (the Act), 112 P.L. 158, added new...more

Federal Bank Secrecy Act Issues for Mobile Payment Systems

In This Presentation: - The BSA from 30,000 Feet - ABCs of the BSA for MSBs - Impact on Customer Acquisition - BSA/AML Enforcement - Current Topics and Resources Excerpt from The BSA from 30,000...more

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