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FinCEN Geographic Targeting Order Imposes Additional Recordkeeping and Reporting Requirements

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

OFAC Terminates License Authorizing Certain Petroleum-Related Activities in Venezuela

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

Trump Administration Announces Designation of International Cartels

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

Trump Threatens Retaliatory Measures vs. Latin American Countries Refusing Repatriation Flights

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

Trump Administration Rescinds Certain Actions by the Previous Administration to Ease Cuba Sanctions

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

U.S. Announces Steps to Ease Cuba Sanctions

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

Corporate Transparency Act Reporting

The Corporate Transparency Act (CTA) requires "Reporting Companies" – domestic entities created by the filing of a document with a secretary of state and non-U.S. entities that have registered to do business in the United...more

FinCEN Issues Final Rule on AML/CFT Requirements for Investment Adviser Sector

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

FinCEN Reference Guide Clarifies Beneficial Ownership Reporting Requirements

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

FinCEN Issues Proposed Rule Amending Requirements of Financial Institutions' AML/CFT Programs

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

OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

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

OFAC Amends Regulations to Support Cuban People, Independent Private-Sector Entrepreneurs

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

CTA Heats Up with New FAQs, Government and Amicus Briefs and New Draft Legislation

The Corporate Transparency Act (CTA) is the gift that keeps giving. As affected entities and their advisers struggle to determine whether they are subject to the beneficial ownership information (BOI) reporting provisions of...more

OFAC Revokes General License 44 Related to Venezuela's Oil and Gas Sector

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

OFAC Suspends Certain U.S. Sanctions with Respect to Venezuela

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

FinCEN Issues Final Rule Implementing Corporate Transparency Act Requirement

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a final rule on Sept. 29, 2022, implementing the beneficial ownership information (BOI) reporting requirement of the Corporate...more

Federal Bank Regulators Issue Joint Guidance on Hemp

Today the federal bank regulatory agencies issued joint guidance on Providing Financial Services to Customers Engaged in Hemp-Related Businesses (Joint Hemp Guidance). These agencies – the Office of the Comptroller of the...more

U.S. Imposes Comprehensive Sanctions Blocking Property of the Government of Venezuela

• 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

Ambassador Bolton Warns of Potential U.S. Secondary Sanctions Against Venezuela - Non-U.S. Entities Transacting with Certain...

• 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

Treasury Designates Additional Maduro Officials, Provides Additional Guidance

• 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

OFAC Designates Petroleos de Venezuela S.A.; U.S. Expands Sanctions on Venezuelan Government - Additional Measures Also Taken...

• 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

New Executive Order Ramps Up Sanctions Against Venezuela and Petroleos de Venezuela S.A.

• 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

FinCEN Proposal Extends AML Requirements to Banks Without a Federal Functional Regulator - Proposed Rule Would Include Trust...

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

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