News & Analysis as of

17 Red Flags for Potential International-Sanctions Violations

Recent events in Ukraine and the Middle East have expanded sanctions placed by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) against certain foreign financial institutions and individuals. This...more

Update on U.S. Sanctions Relating to Ukraine

U.S. Sanctions - On September 12, the United States, in coordination with the EU, imposed additional sanctions against Russia in connection with events in Ukraine. Specifically... - the Office of Foreign Assets...more

New US sanctions on Russia’s financial, defense and energy sectors impact US companies

The US Department of Treasury’s Office of Foreign Assets Control (OFAC) has issued additional sanctions targeting certain Russian banks, energy and defense companies. The sanctions, issued September 12, 2014, are intended to...more

New U.S. Restrictions on Russia: OFAC Guidance and Industry-Specific Sanctions

OFAC Expands the 50 Percent Rule - Last month, the Department of Treasury’s Office of Foreign Assets Control (OFAC) released new guidance related to entities owned or controlled by persons designated as a Specially...more

Bank Settles With OFAC Regarding Civil Action for Apparent Violation of Sudanese Sanctions Regulations

The Office of Foreign Assets Control (“OFAC”) posted a summary of a settlement with a bank (the “Bank”) relating to a transaction that OFAC alleged was processed by the Bank in violation of OFAC’s Sudanese Sanctions...more

OFAC Makes Important Update to Ownership/Control Guidance

On August 13, 2014, the Office of Foreign Assets Control (OFAC) issued new guidance on ownership/control for determining blocked parties. This represented the first significant update on this topic since February 14, 2008,...more

OFAC Issues Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked

The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued revised guidance with respect to entities owned 50 percent or more in the aggregate by one or more blocked persons....more

OFAC Issues New Guidance Regarding Status of Entities Owned by Specially Designated Nationals and Blocked Persons

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new guidance regarding the status of entities that are 50% or more owned by persons or entities whose property and interests in property are...more

New OFAC Guidance on 50% Rule Expands Reach of US Sanctions

The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) revised its guidance with respect to entities owned 50 percent or more in the aggregate by more than one blocked persons. The new guidance, issued on...more

New Sanctions Guidance Increases Due Diligence Burden on Companies

On August 13, 2014, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published guidance (“Revised Guidance”) that revises its 2008 guidance regarding how to treat entities that are owned or...more

OFAC Issues Revised Guidance on Aggregation of Ownership Interests

On August 13, 2014, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued revised guidance with respect to the “50% Rule,” which established that an entity owned 50% or more, directly or indirectly, by a...more

Department of Commerce and OFAC Continue Imposing Hefty Sanctions on Russia, While Russia Retaliates with Own Sanctions

On August 6, the U.S. Department of Commerce (the “Commerce Department”) issued new regulations, implementing additional sanctions against Russia and introducing new restrictions on exports for its energy sector. These new...more

U.S. Department of Commerce Implements New Russian Oil and Gas Sanctions

The sanctions directly affect companies involved in Russia's oil and gas industries by imposing new export license requirements....more

FinCrimes Update - July 2014 Summary, Volumn 1, Issue 5

FINCEN PROPOSES CUSTOMER DUE DILIGENCE RULE - On July 30, FinCEN released a proposed rule that would amend BSA regulations to clarify and add customer due diligence (CDD) obligations for banks and other financial...more

Sanctions Update: Ukraine, Crimea and Sevastopol—the Ukrainian Parliament, the EU and the U.S. impose further measures

This Alert follows our previous alerts on the Russia/Ukraine sanctions available on our website. July continued to be a busy time as the Verkhovna Rada (the Ukrainian Parliament), the EU and the United States intensified...more

EU And US Impose Coordinated Sanctions Against Russia

Following an intense week of diplomatic negotiations, on July 29, the European Union and United States jointly announced a new round of economic sanctions targeting certain sectors of the Russian economy. The development...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

OFAC Announces Substantial Settlement With Bank Over Apparent Sanctions Violations

On July 24, the OFAC released a settlement agreement with a large bank to resolve apparent violations of narcotics sanctions regulations. The settlement agreement states that during separate periods from September 2005...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

U.S. Ukraine-Related Sanctions: Another List to Check and What It Means

On July 16, 2014 in response to the ongoing crisis in Ukraine, the U.S. Office of Foreign Assets Control announced that it was adding several individuals and entities to the Specially Designated Nationals (SDN) list. As with...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

AML BSA and Sanctions Compliance I of II June 10 2014 [Video]

The Department of Justice and the Treasury Department have stepped up AML/BSA and Sanctions Enforcement. With the ever-increasing expansion and modification of sanctions, risks for all businesses, not just financial...more

United States and European Union Ratchet Up Russia Sanctions

On July 16, 2014, the United States ratcheted up its sanctions on Russia in connection with escalating tensions in Eastern Ukraine. Specifically, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”)...more

New Ukraine-Related Sanctions Imposed on Russian Interests

On July 16, 2014, the Obama Administration responded further to developments in Ukraine by imposing another new round of sanctions on Russian, Ukrainian and Crimean parties. Importantly, for the first time, the United States...more

United States Imposes New Sanctions and Export Restrictions Against Russian Banks, Companies, and Individuals

On July 16, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) imposed new sanctions against Russia, which target the country’s financial, energy and defense sectors. In a parallel action, the U.S....more

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