News & Analysis as of

U.S. Treasury Financial Transactions

Holland & Knight LLP

OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

Holland & Knight LLP on

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

Vinson & Elkins LLP

IRS, Treasury Look to Challenge So-Called Basis-Shifting Transactions, But It Won’t Be Easy

Vinson & Elkins LLP on

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) announced the latest chapter in the long-trumpeted enforcement initiative aimed at large partnerships. The guidance, summarized below,...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

The Volkov Law Group

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

The Volkov Law Group on

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

Cadwalader, Wickersham & Taft LLP

Dueling Crypto Banjos: Two Very Different Reactions to Treasury’s Proposed Crypto Reporting Scheme

Treasury recently delivered a mother lode of proposed tax reporting rules to the crypto industry.  By and large, the crypto industry is booing loudly, complaining that the rules are overbroad and that there is not enough time...more

Brownstein Hyatt Farber Schreck

Anniversary of Ukraine Invasion Brings New Sanctions for Russia

On Feb. 24, 2023, the White House announced a slate of additional sanctions against Russia, marking the one-year anniversary of the invasion of Ukraine. The additional sanctions follow President Biden’s recent travel to Kyiv...more

Cadwalader, Wickersham & Taft LLP

New Bipartisan Bill Takes Aim at Digital Asset Money Laundering and Terrorism Finance

On December 14, Senators Elizabeth Warren (D-Mass.) and Roger Marshall (R-Kan.) introduced in the U.S. Senate a new bipartisan bill, titled "Digital Asset Anti-Money Laundering Act of 2022" (the “Bill”), intended to curb the...more

Dechert LLP

OFAC Sanctions Virtual Currency Mixer Tornado Cash

Dechert LLP on

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on August 8, 2022, imposed sanctions against the popular decentralized virtual currency mixer Tornado Cash alleging that it has been used to launder...more

The Volkov Law Group

United States Pushes More Sanctions Against Russia and Prohibits Russian Gold Imports

The Volkov Law Group on

The Department of Treasury issued additional sanctions against Russia, targeting almost 100 entities and individuals, and prohibited import of Russian gold.  The United States’ latest action reflected commitments recently...more

Robinson+Cole Data Privacy + Security Insider

Global Law Enforcement Win: Germany Shuts Down Hydra and U.S. Department of Treasury Follows With Sanctions

In a win for global law enforcement, Germany’s Bundeskriminalamt (BKA) announced on April 5, 2022, that it had officially taken down the infrastructure of Hydra, a Russian-based, illegal dark-web marketplace that has...more

Sheppard Mullin Richter & Hampton LLP

Treasury’s Study Discusses Financial Crimes and NFTs

On February 4, the Department of the Treasury published a study on the facilitation of money laundering and terrorist financing through the art trade. Among other considerations, the report discussed the risks of financial...more

Dechert LLP

U.S. Treasury Signals that Cryptocurrency Miners & Stakers Will Not Be Subject to Broker Information Reporting Tax Requirements

Dechert LLP on

On February 11, 2022, in a letter addressed to certain U.S. Senators, the U.S. Department of the Treasury indicated that cryptocurrency miners, cryptocurrency stakers or related hardware or software providers would not be...more

Sheppard Mullin Richter & Hampton LLP

OFAC Enforcement Impacts NFTs: As Crypto Enforcement Ramps Up to Combat Ransomware, Robust Compliance is Key

The Treasury Department’s Office of Foreign Assets Control (OFAC) took action last Monday, November 8, 2021, and sanctioned a Latvia-based exchange, Chatex, its associated support network, and two ransomware operators for...more

Robinson+Cole Data Privacy + Security Insider

Recent Ransomware Attacks Call for More Oversight of Crypto-Transactions

After the attacks on JBS and Colonial Pipeline, the U.S. Treasury Department will likely consider increasing its enforcement of anti-money-laundering laws and adopt new reporting requirements for cryptocurrency transactions....more

Foodman CPAs & Advisors

IRS is Paying Attention to Virtual Currency Third-Party Information Reporting and Title 26

On September 24, 2020, the TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION (TIGTA) issued a final audit report: “The Internal Revenue Service Can Improve Taxpayer Compliance for Virtual Currency Transactions”  that...more

Stinson - Corporate & Securities Law Blog

Treasury Proposes to Modify CFIUS Mandatory Declaration Requirements

Treasury has proposed rules that would modify provisions in the regulations of the Committee on Foreign Investment in the United States, or CFIUS, that implement the Foreign Investment Risk Review Modernization Act of 2018,...more

Foodman CPAs & Advisors

The U.S.A Continues to be AML/BSA “Vulnerable”

The U.S. Department of the Treasury 2020 Strategy (National Strategy for Combating Terrorist and Other Illicit Financing released on February 6, 2020) describes ongoing significant AML/CFT threats. ...more

Foodman CPAs & Advisors

What is Next after BSA turns 50?

On 2/6/2020, the U.S. Department of the Treasury issued the 2020 National Strategy for Combating Terrorist and Other Illicit Financing (2020 Strategy).  The purpose of the 2020 Strategy is to...more

Polsinelli

CFIUS: Final FIRRMA Regulations Provide New Challenges, Opportunities for Foreign Investors

Polsinelli on

The Department of Treasury has released the final regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”), which contain significant changes to the process by which the Committee on...more

Ballard Spahr LLP

U.S. Treasury and DOJ Targets “Evil Corp”

Ballard Spahr LLP on

Organization Excels at Niche Branding but Stumbles in Avoiding Enforcement - The first paragraph of the press release sums it up: Today the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) took action...more

ArentFox Schiff

The End of Libor

ArentFox Schiff on

For a variety of reasons, as has been widely reported, LIBOR is to cease to be published by the end of 2021 and this expected elimination of the index upon which financing transactions are based raises serious tax and non-tax...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFAC Updates Two General Licenses, Issues Additional Guidance Related to Recent Russia Sanctions

On May 1, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General Licenses 12B and 13A authorizing additional transactions and activities involving certain persons subject to the...more

Akin Gump Strauss Hauer & Feld LLP

Treasury, State and Commerce Implement Regulations Pursuant to the Trump Administration’s Cuba Policy

• On November 9, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State, and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) took coordinated...more

Jones Day

A New Trend? Singapore Company Targeted for U.S. Dollar Payments to Iranian Entities

Jones Day on

The U.S. Department of the Treasury, Office of Foreign Assets Control ("OFAC") recently announced a settlement with CSE TransTel Pte. Ltd. ("TransTel"), a wholly owned subsidiary of CSE Global Limited ("CSE Global"), both of...more

Morgan Lewis

US Government Further Relaxes Trade Restrictions with Cuba

Morgan Lewis on

However, the new transaction rules leave the embargo largely in effect. Early this week, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and...more

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