Earlier this week, the U.S. Office of Foreign Assets Control (OFAC) and the UK Office of Financial Sanctions Implementation (OFSI) published a Memorandum of Understanding (MoU), which was previously signed on October 9, 2024,...more
On April 11, 2024, the U.S. Department of the Treasury (Treasury), as Chair of the Committee on Foreign Investment in the United States (CFIUS), issued a Notice of Proposed Rulemaking (NPRM), which is the first substantive...more
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
3/27/2024
/ Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Transactions ,
Foreign Corporations ,
Foreign Direct Product Rule ,
Foreign Jurisdictions ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Risk Assessment ,
Risk Mitigation ,
Trade Relations ,
U.S. Commerce Department ,
U.S. Treasury
On November 6, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) announced a $206,213 settlement with Swift Prepaid Solutions, Inc. d/b/a daVinci Payments (daVinci) for apparent violations of...more
The Biden Administration has launched a comprehensive effort to develop a cohesive policy approach for digital assets.
Key agencies are instructed to report on digital asset issues and legal framework in relation to...more
3/14/2022
/ Anti-Money Laundering ,
Biden Administration ,
Central Bank Digital Currency (CBDCs) ,
CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Non-Fungible Tokens (NFTs) ,
Securities ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury
On February 24, 2022, the U.S. Government issued a number of sanctions measures in response to Russia’s attack on Ukraine. These measures include sweeping financial sanctions and stringent export controls, which will have...more
2/25/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Embargo ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
U.S. Treasury ,
Ukraine
Last week, the U.S. Department of the Treasury released a report entitled “Study of the Facilitation of Money Laundering and Terror Finance Through the Trade in Works of Art” that discussed risks in the art sales ecosystem,...more
E.O. 14032 signals that the Biden Administration will continue to restrict U.S. investments into China’s defense and surveillance technology sectors.
The prior Administration’s November 2020 Executive Order (E.O.) 13959...more
New federal requirements in the annual national defense budget reauthorization effectively will end anonymous U.S. shell companies by requiring businesses to disclose 25 percent owners and control persons to a newly created...more
1/6/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Drug Trafficking ,
Financial Institutions ,
FinCEN ,
Fraud ,
Guidance Update ,
Human Trafficking ,
Law Enforcement ,
Patriot Act ,
Penalties ,
Regulatory Requirements ,
Reporting Requirements ,
Shell Corporations ,
Terrorist Acts ,
U.S. Treasury ,
Virtual Currency ,
Whistleblowers
The U.S. Treasury Department has issued sanctions designations against Turkey’s Ministry of National Defense, Ministry of Energy and Natural Resources, and the Minsters of Defense, Energy and Interior pursuant to a new...more
As it targets terrorist groups and their finances, the U.S. Government announces potent secondary sanctions that can impede correspondent banking relationships of non-U.S. banks.
A new U.S. Executive Order updates the...more
9/12/2019
/ Anti-Money Laundering ,
Due Diligence ,
Entity List ,
Executive Orders ,
Financial Institutions ,
Foreign Banks ,
Non-Bank Lenders ,
SDN List ,
Terrorism Funding ,
Terrorist Financing Regulations ,
U.S. Treasury
The Treasury Department has placed several prominent Russian individuals and companies on the Specially Designated Nationals and Blocked Persons lists (“SDN list”). Several of these parties are Russian billionaires previously...more
The Office of Financial Sanctions Implementation ramps up enforcement activities in London -
A new UK sanctions enforcement body with added civil enforcement tools is ramping up activities. ...more
11/1/2017
/ Economic Sanctions ,
EU ,
Financial Institutions ,
HM Treasury ,
International Finance ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Policing and Crime Act 2017 ,
U.S. Treasury ,
UK ,
Voluntary Disclosure
The United Nations and United States recently took significant new steps to expand sanctions on North Korea, with implications for international banking; shipping and port activities; air transport; energy and mining sectors;...more
4/4/2016
/ Censorship ,
Economic Sanctions ,
Embargo ,
Executive Orders ,
Human Rights ,
International Finance ,
North Korea ,
Oil & Gas ,
Shipping ,
U.S. Treasury ,
UN Security Council
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking on August 25, 2015 which, among other things, would add SEC-registered investment advisers to the “financial...more
9/2/2015
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Currency Transaction Reports (CTR) ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
On January 20, 2014, the U.S. Treasury and State Departments took steps to implement temporary and limited changes to U.S. sanctions policy for Iran as agreed under the interim nuclear deal reached by Iran and the P5 + 1...more