The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO) as part of a "whole-of-government approach" to leverage all...more
3/14/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Cartels ,
Executive Orders ,
Financial Services Industry ,
FinCEN ,
Geographic Targeting Order ,
Human Trafficking ,
Money Laundering ,
Reporting Requirements ,
Significant Transnational Criminal Organization ,
Trump Administration ,
U.S. Treasury
President Donald Trump announced on Feb. 26, 2025, that he was reversing the authorization granted to Chevron Corp. and its subsidiaries (Chevron) by the Biden Administration as a concession aimed at promoting free elections...more
3/7/2025
/ Chevron ,
Economic Sanctions ,
Energy Sector ,
Financial Services Industry ,
Foreign Investment ,
General Licenses ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Subsidiaries ,
Trump Administration ,
U.S. Treasury ,
Venezuela
U.S. President Donald Trump issued Executive Order 14157 (the EO) on Jan. 20, 2025, calling for the designation of drug cartels and other foreign organizations as foreign terrorist organizations (FTOs) or specially designated...more
President Donald Trump on Jan. 20, 2025, issued various immigration-related Executive Orders (EOs) and presidential actions that could have an immediate and lasting impact on Latin American countries. President Trump's...more
2/3/2025
/ Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Immigration Procedures ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Latin America ,
Office of Foreign Assets Control (OFAC) ,
Retaliation ,
Tariffs ,
Trump Administration
Within hours after taking office on Jan. 20, 2025, U.S. President Donald Trump signed an omnibus executive order revoking 78 executive actions by the previous administration, dating back to 2021. Among them, President Trump...more
Besides certain expansions on remittances in 2022, the White House, on Jan. 14, 2025, issued a statement announcing President Joe Biden's plans to relax sanctions on Cuba through a series of broad measures aimed at improving...more
1/17/2025
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Cuba ,
Economic Sanctions ,
Export Controls ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
State Sponsors of Terrorism ,
Trump Administration ,
U.S. Treasury
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Aug. 28, 2024, issued a final rule to help safeguard the investment adviser sector from illicit finance activity (Final Rule). The Final...more
9/6/2024
/ AML/CFT ,
Bank Secrecy Act ,
Biden Administration ,
Compliance ,
Customer Due Diligence (CDD) ,
Final Rules ,
Financial Institutions ,
FinCEN ,
NPRM ,
Popular ,
Registered Investment Advisors ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 26, 2024, issued a notice containing a reference guide for customers of financial institutions (the Reference Guide). The Reference...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on June 28, 2024, announced a proposed rule to "strengthen and modernize financial institutions' anti-money laundering and countering the...more
7/15/2024
/ AML/CFT ,
Anti-Money Laundering ,
Board of Directors ,
Compliance ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Oversight Committee ,
Proposed Rules ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding
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
6/25/2024
/ Biden Administration ,
Compliance ,
Economic Sanctions ,
Evasion ,
Executive Orders ,
Financial Transactions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
U.S. Treasury
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR), 31 CFR Part 515, to promote internet freedom in Cuba, support independent Cuban private-sector...more
5/30/2024
/ Amended Regulation ,
Bank Accounts ,
Banking Sector ,
Biden Administration ,
Blocked Person ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Development ,
Entrepreneurs ,
Financial Services Industry ,
Foreign Nationals ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Private Sector ,
SDN List
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License 44A (GL 44A) on April 17, 2024, replacing and superseding General License 44 (GL 44). On Oct. 18, 2023, OFAC suspended...more
Please join Holland & Knight's Financial Services Regulatory Team for a roundtable discussion on what to expect on the financial services landscape in 2024. Our attorneys will present on a wide range of topics in a "3-Minute...more
1/3/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Continuing Legal Education ,
Federal Trade Commission (FTC) ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Regulatory Agencies ,
Financial Services Industry ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Securities and Exchange Commission (SEC) ,
Webinars
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 18, 2023, suspended certain U.S. sanctions under the Venezuela Sanctions Regulations (VSR), including measures on Venezuela's oil and gas...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) released proposed regulations on Jan. 24, 2022, for implementing a pilot program allowing financial institutions to share suspicious activity...more
1/28/2022
/ Anti-Money Laundering ,
Comment Period ,
Financial Institutions ,
FinCEN ,
Foreign Jurisdictions ,
Foreign Subsidiaries ,
Internal Controls ,
Proposed Regulation ,
Reporting Requirements ,
Subsidiaries ,
Suspicious Activity Reports (SARs)
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) released proposed regulations on Dec. 7, 2021, seeking to implement the "beneficial ownership information" (BOI) requirement of the Corporate...more
12/15/2021
/ AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
Commodity Exchange Act (CEA) ,
Corporate Transparency Act ,
Disclosure Requirements ,
FinCEN ,
NPRM ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more
7/7/2021
/ AML/CFT ,
Anti-Corruption ,
Anti-Money Laundering ,
Banking Sector ,
Biden Administration ,
Cyber Crimes ,
Drug Trafficking ,
Enforcement Priorities ,
Financial Institutions ,
FinCEN ,
Fraud ,
Human Trafficking ,
Mexico ,
Money Laundering ,
New Guidance ,
Nonbank Firms ,
Office of Foreign Assets Control (OFAC) ,
Policy Statement ,
Popular ,
Russia ,
Significant Transnational Criminal Organization ,
Smuggling ,
State Sponsors of Terrorism ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing Regulations ,
U.S. Treasury ,
Virtual Currency
The Anti-Money Laundering Act of 2020 (AMLA 2020) became law on Jan. 2, 2020, when Congress overrode President Donald Trump's veto of the National Defense Authorization Act. AMLA 2020 is the most consequential anti-money...more
1/14/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Congressional Override ,
Criminal Penalties ,
Customer Due Diligence (CDD) ,
Financial Institutions ,
FinCEN ,
Foreign Banks ,
Mutual Legal Assistance Treaties (MLAT) ,
NDAA ,
Presidential Veto ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers
In an effort to curb the Cuban regime from "redirecting revenue from authorized U.S. travel for its own benefit," as stated by U.S. Department of the Treasury Secretary Steven T. Mnuchin, the Office of Foreign Assets Control...more
• President Donald Trump has issued an Executive Order expanding the current sanctions relating to Venezuela by blocking all property and interests in property of the government of Venezuela and the Nicolás Maduro...more
8/8/2019
/ Banking Sector ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
General Licenses ,
Human Rights ,
Humanitarian Assistance ,
Office of Foreign Assets Control (OFAC) ,
Politically Exposed Person (PEPs) ,
SDN List ,
Secretary of the Treasury ,
Trump Administration ,
Venezuela
• 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 Securities (BIS) announced changes to the Cuban Assets Control Regulations (CACR)...more
6/6/2019
/ Aircraft ,
Airline Passengers ,
Bureau of Industry and Security (BIS) ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Export Administration Regulations (EAR) ,
Federal Aviation Administration (FAA) ,
Foreign Relations ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
p2p ,
Sanctions ,
Trump Administration ,
Vessels
• Effective May 2, 2019, the Trump Administration will not continue the waiver against lawsuits under Title III of the Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996, also known as the Helms-Burton Act.
•...more
4/26/2019
/ Civil Liability ,
Cuba ,
Extraterritoriality Rules ,
Foreign Nationals ,
International Travel ,
Office of Foreign Assets Control (OFAC) ,
Personal Jurisdiction ,
Trafficking ,
Trump Administration ,
US State Departments ,
WTO
• National Security Advisor Ambassador John Bolton issued a statement threatening sanctions against non-U.S. banks for facilitating illegitimate transactions with certain Venezuelan individuals and entities.
• This...more
3/14/2019
/ Banking Sector ,
Blocked Entities ,
Cross-Border Transactions ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Venezuela
• The Trump Administration is allowing U.S. nationals to pursue civil actions against certain Cuban entities under Title III of the Helms-Burton Act (Libertad Act) for trafficking in property confiscated by the Cuban...more
• The U.S. Department of the Treasury's (Treasury) Office of Foreign Assets Control (OFAC) has designated five officials affiliated with the regime of Nicolas Maduro pursuant to Executive Order 13850 (E.O. 13850), including...more