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FinCEN proposes expanding Bank Secrecy Act requirements to certain investment advisers

On February 13, 2024, U.S. Department of the Treasury’s Financial Crimes Enforcement Network issued a Notice of Proposed Rulemaking seeking to expand the Bank Secrecy Act’s definition of “financial institution” to include...more

New Russia sanctions target foreign financial institutions and imports of certain products

On December 22, 2023, President Biden issued a new Russia-related Executive Order (“EO”) targeting foreign financial institutions (“FFIs”) that support Russia’s military-industrial base. The new EO allows the U.S. government...more

Summary of February 24 U.S. sanctions and export controls on Russia

On February 24, 2022, the US Government imposed severe economic sanctions and export controls on Russia. The restrictions consist of two parts: 1) significant financial sanctions on a range of Russian financial institutions...more

Biden Administration sanctions target Russian technology and defense sectors and Russian sovereign debt

On 15 April 2021, the U.S. Government announced a number of new sanctions measures against Russia, targeting a variety of “harmful foreign activities” contrary to U.S. foreign policy. ...more

Treasury Department issues ransomware guidance in response to significant uptick in ransomware attacks

In response to the significant rise in ransomware attacks since the start of the COVID-19 pandemic and just in time for Cybersecurity Awareness Month, the Department of the Treasury’s Financial Crimes Enforcement Network...more

O sanction! My sanction! Sanctions, banks, and Southeast Asia - SEA View, April 2019

SEA View: Our new monthly periodical has launched! From April 2019, this periodical will feature investigation, compliance, and regulatory developments in Southeast Asia (SEA). For a twelve-month spell, one monthly article...more

Re-imposing sanctions on Iran, Trump discards nuclear deal

On 5 November 2018 the United States re-imposed the remaining nuclear-related secondary sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) against Iran that previously had...more

Iran sanctions: Snapback becomes reality

The United States has begun re-imposing nuclear-related sanctions with respect to Iran in connection with the expiration of the 90-day wind-down period announced alongside the United States' 8 May 2018 withdrawal from the...more

A guide to NYDFS Cybersecurity Regulation's March 1 implementation deadline

It’s been almost a year since the New York State Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) came into effect. Since that time, a series of key dates have marked the implementation of...more

New executive order targets Venezuela’s access to U.S. financial markets

Effective August 25, 2017, President Trump issued a new Executive Order, (the Order), which targets the Government of Venezuela’s (GOV) and Petroleos de Venezuela, S.A.’s (PdVSA) ability to access capital from the United...more

UK Financial Sanctions: Extended Reporting Requirements

On 8 August 2017, the European Union Financial Sanctions (Amendment of Information Provisions) Regulations 2017 (the "Regulations") will come into force. The Regulations "expand the scope of the reporting requirements set out...more

Anti-Money Laundering and Cybersecurity Among the 2017 SEC Examination Priorities

Earlier this month, the Securities and Exchange Commission (SEC) announced its Office of Compliance Inspections and Examinations’ (OCIE) 2017 Examination Priorities regarding certain practices, products, and services that...more

The Obama Administration Eases Sanctions Against Sudan

On January 13, 2017, the White House, the U.S. Department of Treasury ’s Office of Foreign Assets Control (OFAC) , and the U.S. Department of Commerce ’s Bureau of Industry and Security (BIS) announced a host of policy...more

New York Department of Financial Services Cybersecurity Rules Revised and Delayed

The New York Department of Financial Services (NYDFS) just issued major revisions to the cybersecurity regulations for financial institutions that were due to come into effect on January 1, 2017. To allow covered institutions...more

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