Deputy Attorney General (DAG) Lisa Monaco once again delivered groundbreaking remarks at the American Bar Association (ABA) National Institute on White Collar Crime (ABA White Collar Conference) on March 2, 2023, this time...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), on August 8, 2022, sanctioned virtual currency mixer Tornado Cash. OFAC alleged that it had been “used to launder more than $7 billion worth of...more
As Russia’s invasion of Ukraine persists, with no end currently in sight, the United States continues to issue increasingly punishing economic sanctions and export controls targeting Russia, most recently aiming at the...more
5/17/2022
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Entities ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Professional Services Companies ,
Russia ,
Ukraine
Russia’s invasion into Ukraine in February 2022 has prompted the United States and its allies, including the United Kingdom, the European Union, and others, to issue substantial international trade restrictions such as...more
4/21/2022
/ Banks ,
Belarus Sanctions ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trade Relations ,
Trade Restrictions ,
UK ,
Ukraine
Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more
3/22/2022
/ Anti-Money Laundering ,
Anti-Terrorism Financing ,
Bank Secrecy Act ,
Belarus ,
Bureau of Industry and Security (BIS) ,
Convertible Virtual Currencies (CVCs) ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
FinCEN ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Russia ,
SDN List ,
SWIFT ,
U.S. Treasury ,
UK ,
Ukraine
On February 21, 2022, Russian President Vladimir Putin unilaterally recognized the Luhansk and Donetsk regions in Eastern Ukraine (Covered Regions) as independent states. Thereafter, Mr. Putin authorized a full-scale invasion...more
3/3/2022
/ Banking Sector ,
Bureau of Industry and Security (BIS) ,
CAPTA List ,
Economic Sanctions ,
Export Controls ,
Exports ,
Financial Institutions ,
Financial Transactions ,
FinTech ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Sovereign Debt ,
SWIFT ,
Ukraine
Agency’s Focus on Cryptocurrency and Blockchain Continues -
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an updated advisory to “highlight the sanctions...more
10/5/2021
/ Crypto Exchanges ,
Currency Exchange ,
Cyber Attacks ,
Cybersecurity ,
Economic Sanctions ,
Enforcement Actions ,
Guidance Update ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
U.S. Treasury ,
Virtual Currency
The Office of Foreign Assets Control (OFAC), an agency of the U.S. Department of the Treasury, administers and enforces U.S. economic sanctions programs against targeted foreign governments, individuals, groups and entities...more
5/8/2019
/ Audits ,
Chief Compliance Officers ,
Corporate Counsel ,
Corporate Officers ,
Economic Sanctions ,
Enforcement Actions ,
Internal Controls ,
National Security ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Risk Assessment ,
Senior Managers
The United States will reimpose sanctions against Iran to implement President Donald Trump’s decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), a multilateral agreement under which Iran agreed to curb...more
A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran? This update summarizes the...more
6/9/2017
/ Appeals ,
Corporate Liability ,
Distributors ,
Due Diligence ,
Electronics ,
Enforcement Actions ,
Export Controls ,
Exports ,
Iran ,
Iran Sanctions ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
United Arab Emirates (UAE)
The United States suspended certain “secondary sanctions” against Iran that apply to non-U.S. companies for transactions that take place outside of the United States and do not involve U.S. persons on “Implementation Day,”...more
President Obama recently issued Executive Order 13694 (EO 13694 or EO), “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities.” EO 13694 is aimed at deterring cyber attacks,...more
When the White House recently announced that it was extending sanctions against Russia for another year, it cited a continued “unusual and extraordinary threat” from Russia’s activities in Ukraine. President Obama also...more
During the same week that President Barack Obama announced sweeping changes in the diplomatic and trade relationships between the United States and Cuba, the president signed congressional legislation authorizing additional...more
1/7/2015
/ Banking Sector ,
Barack Obama ,
Corporate Counsel ,
Crimea ,
Cuba ,
Defense Sector ,
Drug Trafficking ,
Energy Sector ,
EU ,
European Commission ,
Executive Orders ,
Export Controls ,
Illegal Arms Dealers ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
Ukraine ,
US Trade Policies ,
Venezuela
The United States agreed to suspend certain sanctions against Iran over the weekend as part of an agreement to curb the Iranian nuclear program. The agreement, which provides for a six-month first step towards a...more