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Reporting Requirements Economic Sanctions

Akin Gump Strauss Hauer & Feld LLP

UK Government Announces New Civil Enforcement Powers on Trade Sanctions and Launch of Office of Trade Sanctions Implementation

Key Takeaways - On 12 September 2024, the UK government published the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations”), which will come into force on 10 October 2024. The...more

Foley Hoag LLP

OFAC Publishes Both Interim Final Rule Extending Recordkeeping Requirements and Comment Request Regarding its Information...

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OFAC issued an interim final rule extending OFAC’s recordkeeping requirements from 5 years to 10 years, to comport with the corresponding statute of limitations extension. OFAC also published a request for public comment...more

Baker Botts L.L.P.

OFAC Extends Recordkeeping Requirements for All Sanctions Programs

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In an era of active U.S. sanctions policy, it is not uncommon to see the Office of Foreign Assets Control (“OFAC”) issue a notice changing U.S. sanctions – promulgating a new sanctions program or updating the designation of a...more

Mayer Brown

UK Government Launches Office of Trade Sanctions Implementation to Enforce UK Trade Sanctions

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On 12 September 2024, the UK Government published the regulatory framework providing the scope and powers of the Office of Trade Sanctions Implementation (OTSI), the authority responsible for the implementation and...more

Stikeman Elliott LLP

Sanctions Evasion: Canada Takes Aim with New FINTRAC Reporting Requirements for Reporting Entities

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Reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) will soon be subject to a new requirement to report transactions suspected to be related to sanctions evasion to the...more

Seward & Kissel LLP

Compliance Flash: OFAC Announces New Reporting Requirement for Financial Institutions Under the REPO for Ukrainians Act

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The supplemental appropriations legislation signed into law on April 24, 2024 enacted numerous high-profile provisions addressing aspects of U.S. foreign policy and national security, including provisions that broaden and...more

White & Case LLP

The Shadow Financial System

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The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

Hogan Lovells

OFAC issues interim final rule amending blocked property and other reporting requirements

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The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an interim final rule set to take effect August 8, 2024, which amends the Reporting, Procedures, and Penalties Regulations (the “Regulations”)...more

White & Case LLP

EU establishes harmonized enforcement and penalties for sanctions violations

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The EU has adopted a new directive which establishes EU-wide rules for defining criminal offences and penalties related to the violation of EU sanctions. A stricter regulatory environment and closer scrutiny is expected as...more

Sheppard Mullin Richter & Hampton LLP

No More Postcards to OFAC in 2024: Unpacking OFAC’s New Reporting Procedures

On May 10, 2024, The Office of Foreign Assets Control (OFAC) has released a new proposed rule which would make significant changes to OFAC’s standard reporting, record-keeping, and license applications under U.S. sanction...more

Akin Gump Strauss Hauer & Feld LLP

Congress Extends Statute of Limitations for Sanctions and Certain Other National Security Programs from 5 to 10 Years and...

While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Publishes First Sanctions Strategy and New Licensing Guidance

On 22 February 2024, shortly before the second anniversary of Russia’s invasion of Ukraine, the UK government published its first sanctions strategy (the Strategy). The Strategy explains the UK’s use and implementation of...more

Venable LLP

Alabama Federal District Court Declares CTA Unconstitutional: Here's What You Need to Know

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The Corporate Transparency Act (CTA), which became effective on January 1, 2024, was enacted to combat the use of shell companies by those seeking to evade anti-money laundering laws and economic sanctions. ...more

Torres Trade Law, PLLC

Trade Due Diligence in the Context of an IPO

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Ensuring compliance with U.S. export controls, import regulations, and economic sanctions is common practice for companies that engage in international trade. These companies often have internal compliance policies and due...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Announces Creation of New Trade Sanctions Enforcement Agency and Introduces Further Sanctions Against Russia

With Russia’s invasion of Ukraine nearing the end of its second year, the United Kingdom has continued to introduce sanctions measures against Russia, with the latest round announced on 14 December 2023....more

Davis Wright Tremaine LLP

FINRA’s 2024 Annual Regulatory Oversight Report: Select Observations

FINRA recently published its 90-page 2024 Annual Regulatory Oversight Report (Report) providing member firms with insight into six primary topics: Financial Crimes, Crypto Asset Development, Firm Operations, Communications...more

American Conference Institute (ACI)

[Event] 8th Annual Canadian Forum on Global Economic Sanctions - March 6th - 7th, Toronto, ON, Canada

Immerse yourself in the only comprehensive economic sanctions event of its kind in Canada, spanning two days of invaluable insights and practical knowledge. Designed to cover U.S., EU, and major global sanctions, this...more

Skadden, Arps, Slate, Meagher & Flom LLP

EU Further Strengthens Restrictive Measures Against Russia in 12th Package of Sanctions

On 18 December 2023, the European Union adopted a 12th package of sanctions against Russia. The sanctions impose an asset freeze on more than 140 individuals and entities pursuant to Council Regulation (EU) 269/2014...more

Akin Gump Strauss Hauer & Feld LLP

New EU & UK Sanctions

EU’s 12th Sanctions Package - On 19 December 2023, the Council of the European Union (EU) together with the Commission published its 12th round of sanctions....more

K&L Gates LLP

Brussels Regulatory Brief: November 2023

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Antitrust and Competition - European Commission Approves Consolidation in the Ground Transportation Sector Subject to Remedies - The companies are two global suppliers of signalling systems for mainline and urban railway...more

K&L Gates LLP

Brussels Regulatory Brief: August-September 2023

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ANTITRUST AND COMPETITION - The European Commission’s Merger Simplification Package Enters Into Force - On 20 April 2023, the European Commission (Commission) adopted a new legislative package that entered into force on 1...more

The Volkov Law Group

Reminder to file your 2023 Annual Report of Blocked Property: Due date September 30, 2023

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On September 22, 2023, the U.S. Department of Treasury Office of Foreign Assets Control (“OFAC”) issued its “Reminder to file your 2023 annual report of Blocked Property,” noting that entities or persons subject to the...more

A&O Shearman

UK sanctions systems and controls: lessons learnt

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The UK Financial Conduct Authority (FCA) has assessed the systems and controls relating to sanctions compliance for over 90 firms across a range of sectors and summarised its findings of good and poor practice. Acknowledging...more

K&L Gates LLP

United States Imposes Unprecedented Outbound Investment Controls Focused on China

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On 9 August 2023, President Biden issued a long anticipated executive order imposing certain limitations, reporting requirements, and prohibitions on outbound investment from the United States into certain sensitive industry...more

Conyers

Cayman Islands Issues General Licence for Payment of Legal Fees

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On 14 April 2023, the Governor of the Cayman Islands issued a general licence (GL/2023/0002) for the payment of legal fees (the “Cayman General Licence”). This means that, under specified circumstances, Designated Persons...more

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