On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more
3/25/2025
/ Anti-Money Laundering ,
Blockchain ,
Chevron Deference ,
Compliance ,
Cryptocurrency ,
Delisting ,
Digital Assets ,
Economic Sanctions ,
International Emergency Economic Powers Act (IEEPA) ,
Loper Bright Enterprises v Raimondo ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Risk Management ,
SCOTUS ,
SDN List ,
U.S. Treasury
On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more
10/22/2024
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Country of Origin ,
Due Diligence ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Foreign Policy ,
Foreign Trade Zones ,
Jurisdiction ,
Military End Use ,
National Security ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Risk Assessment ,
Russia ,
SDN List ,
Self-Disclosure Requirements ,
Suspicious Activity Reports (SARs) ,
Voluntary Disclosure
On 12 June 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued new measures to further isolate Russia’s...more
6/18/2024
/ Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Dubai Economic Security Center (DESC) ,
EU ,
Exports ,
Foreign Financial Institutions (FFI) ,
Jurisdiction ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Shell Corporations ,
Software ,
U.S. Commerce Department ,
Ukraine
On 24 April 2024, President Biden signed into law H.R. 815, “Making Emergency Supplemental Appropriations for the Fiscal Year Ending September 30, 2024, and for Other Purposes” (the Act). The long-awaited piece of legislation...more
5/14/2024
/ Biden Administration ,
China ,
Data Protection ,
Energy Sector ,
Export Controls ,
Exports ,
Financial Institutions ,
Foreign Adversaries ,
Foreign Aid ,
Hamas ,
Imports ,
Iran Sanctions ,
Israel ,
Israel/Palestine ,
Legislative Agendas ,
New Legislation ,
Popular ,
Russia ,
Sanction Violations ,
Sanctions ,
Statute of Limitations ,
Taiwan ,
Technology Sector ,
Terrorist Organizations ,
Trafficking ,
Ukraine
On 22 December 2023, the Biden administration issued Executive Order 14114, “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” (EO 14114), thereby amending EOs 14024 and 14068. The new EO...more
1/11/2024
/ Aerospace ,
Biden Administration ,
CAPTA List ,
Construction Industry ,
Defense Sector ,
Due Diligence ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Financial Services Industry ,
Foreign Financial Institutions (FFI) ,
Importers ,
Licenses ,
Manufacturing Facilities ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanction Violations ,
SDN List ,
Semiconductors ,
Technology Sector ,
Transparency ,
US State Departments
Summary of What Has Happened and What Is Yet to Come -
On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more
11/14/2023
/ Convertible Virtual Currencies (CVCs) ,
Department of Justice (DOJ) ,
Employee Benefits ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Popular ,
Proposed Regulation ,
Recordkeeping Requirements ,
Reporting Requirements ,
Risk Assessment ,
Risk Management ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing ,
Transparency ,
Virtual Currency
The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more
8/15/2023
/ Bank Secrecy Act ,
Bureau of Industry and Security (BIS) ,
Code of Federal Regulations (CFR) ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Investigations ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Russia ,
Self-Disclosure Requirements ,
Third-Party ,
U.S. Treasury ,
Voluntary Disclosure ,
Whistleblowers
Chinese lawmakers approved revisions to the country’s counterespionage law on 23 April 2023, broadening the definition of spying and banning the transfer of any information related to national security interests (which are...more
5/16/2023
/ CFIUS ,
China ,
Cybersecurity ,
Economic Sanctions ,
Espionage ,
Forced Labor ,
Foreign Corporations ,
Human Rights ,
International Data Transfers ,
Investors ,
National Security ,
Popular
The United States Department of the Treasury has continued to signal that it will focus policy, regulatory, and enforcement attention on the financial crime and sanctions risk in the crypto and digital asset ecosystem...more
10/26/2022
/ Anti-Money Laundering ,
Anti-Terrorism Financing ,
Cryptocurrency ,
Digital Assets ,
Economic Sanctions ,
Enforcement ,
Financial Crimes ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Oversight ,
Risk Assessment ,
Risk Management ,
U.S. Treasury