• Pursuant to Executive Order 13850 (E.O. 13850), the U.S. Department of the Treasury's (Treasury) Office of Foreign Assets Control (OFAC) designated Petroleos de Venezuela, S.A. (PdVSA), effectively blocking PdVSA's property...more
1/31/2019
/ Banking Sector ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Petroleum ,
SDN List ,
Trump Administration ,
Venezuela
• President Donald Trump has issued an Executive Order (the E.O.) imposing additional sanctions with respect to the situation in Venezuela, and the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has...more
8/29/2017
/ Blocked Person ,
Citgo ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
SDN List ,
Trump Administration ,
Venezuela
• The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) continues to expand its Geographic Targeting Orders (GTOs) with respect to beneficial ownership transparency in real estate...more
On July 25, 2017, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a revised set of frequently asked questions (FAQs) further clarifying the scope and implementation process for the...more
7/31/2017
/ Amended Regulation ,
Contract Terms ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Grandfathered Status ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Travel Restrictions ,
Trump Administration ,
U.S. Treasury
On the afternoon of June 16, 2017, shortly before President Donald Trump announced new changes to the U.S.-Cuba policy, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued 12 frequently asked...more
6/19/2017
/ Cross-Border Transactions ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Exports ,
Imports ,
International Remittance Transfers ,
Military Contracts ,
Travel Restrictions ,
Trump Administration
The Financial Crimes Enforcement Network (FinCEN) on Aug. 25, 2016, issued a notice of proposed rulemaking (Proposed Rule) to implement Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools...more
8/29/2016
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Financial Institutions ,
FinCEN ,
Non-Resident Aliens ,
Puerto Rico ,
Regulatory Standards ,
Virgin Islands
In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more
5/20/2016
/ Bank Accounts ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Corporate Counsel ,
Corruption ,
Criminal Investigations ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
FATCA ,
Financial Institutions ,
FinCEN ,
Foreign-Owned Corporations ,
Geographic Targeting Order ,
IRS ,
Money Laundering ,
Mossack Fonseca ,
Office of Foreign Assets Control (OFAC) ,
Offshore Funds ,
Panama Papers ,
Shell Corporations ,
Tax Evasion ,
Tax Haven ,
Wire Transfers
On April 21, 2015 – after months of speculation by those in the Bank Secrecy Act/anti-money laundering compliance community – the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in...more
A pre-release of the revised regulations from the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce Bureau of Industry and Security (BIS) identifies the extensive changes in...more
August was a busy month for the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). Among other initiatives, FinCEN issued its long-awaited proposed regulations on customer due diligence (CDD)...more
9/4/2014
/ Advisory Opinions ,
AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Compliance ,
Cross-Border Transactions ,
Due Diligence ,
Enforcement Actions ,
FATF ,
Financial Institutions ,
FinCEN ,
Mexico ,
Proposed Regulation ,
Rulemaking Process
On Aug. 11, 2014, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued FIN-2014-A007 (the "Advisory"). Among other things, the Advisory highlights the importance of maintaining a strong...more