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FinCEN Issues Final Rule on Beneficial Ownership Reporting Under the CTA

On September 29, 2022, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a long-awaited final rule implementing the beneficial ownership information (BOI) reporting requirements of the...more

US, UK and EU Expand and Amend Russian Sanctions, Responding to Purported Annexations of Ukrainian Regions

In light of the recent referendums and purported annexation by Russia of four territories of Ukraine on September 30, 2022, the United States, United Kingdom and European Union have expanded measures and provided additional...more

Treasury and Justice Department Reports Signal Tougher Enforcement and Regulation in the Digital Assets Sector

On September 16, 2022, the U.S. Department of the Treasury and Department of Justice released four much-anticipated reports on different aspects of cryptoasset regulation. They confirm the Biden administration’s broad but...more

US Adopts Further Sanctions and Export Controls Targeting Russia

Even though significant sanctions and export controls have already been put in place, the United States recently adopted additional measures targeting key elements of the Russian economy and military industry in response to...more

US, UK and EU Impose New Sanctions and Export Controls on Key Elements of Russian Economy

Since the publication of our March 24, 2022, and March 17, 2022, client alerts, the U.S., U.K. and European Union, among other allied nations, have imposed additional sanctions and export controls on key elements of the...more

UK and EU Impose Further Ukraine-Related Sanctions on Russia and Belarus

Since the publication of our 9 March 2022 client alert, the US, UK and EU and other allied nations have imposed additional sanctions and export controls on key elements of the Russian economy. This client alert summarizes the...more

New US Restrictions Impact Russia-Related Imports and Exports, US Dollar-Denominated Banknotes

On March 11, 2022, President Joe Biden signed Executive Order 14068 (E.O. 14068) imposing new restrictions on imports and exports with respect to Russia as well as on the supply of U.S. dollar-denominated banknotes to the...more

US Bans Russian Oil Imports and Restricts Investment in Russia’s Energy Sector

On March 8, 2022, President Joe Biden issued Executive Order (E.O.) 14066, which bans the import of Russian oil, gas and other energy products into the United States and imposes sweeping prohibitions on new U.S. investment in...more

US, UK and EU Ramp Up Sanctions and Export Controls as Russia’s Invasion of Ukraine Continues

Since the publication of our February 26, 2022, client alert, the United States, United Kingdom and the European Union, among other allied nations, have imposed additional sanctions and export controls on key elements of the...more

US, UK and EU Impose Significant Sanctions and Export Controls in Response to Russia’s Invasion of Ukraine

The United States, United Kingdom and the European Union, among other allies, have moved swiftly in response to the Russian Federation’s invasion of Ukraine. Merely hours after Russia’s announcement on February 21, 2022, that...more

District Court Upholds OCC and FDIC ‘Valid When Made’ Rules

On February 8, 2022, a federal district court in California issued two opinions, granting summary judgment to the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) and...more

The Federal Reserve Weighs Risks and Benefits of a US Central Bank Digital Currency

This is the fourth in a series of articles in which we discuss recent efforts by regulators and other governmental bodies to set expectations and standards, or pursue governmental initiatives, with respect to cryptocurrencies...more

Central Banks Consider Digital Currency Pros and Cons in US and Europe

Takeaways - The Bank for International Settlements and seven central banks are studying how to launch CBDCs and have flagged key issues that will need to be addressed, including interoperability and confidentiality. In...more

Navigating the Future Landscape of the EU Blocking Statute

The European Union Blocking Statute was originally adopted in 1996 to counteract US sanctions on Cuba, Iran and Libya, but following a memorandum of understanding entered into between the EU and the US, it has seldom been...more

FinCEN Issues Long-Awaited Proposed Rule To Implement New Beneficial Ownership Reporting Requirements

On December 7, 2021, the Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated notice of proposed rulemaking (the Proposed Rule) to implement the beneficial ownership reporting...more

Federal Regulators Move To Regulate Stablecoins Through Banking Laws Plus New Legislation

The President’s Working Group on Financial Markets (PWG), together with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), released a much-anticipated Report on...more

FATF Updates Its Global Guidelines for the Regulation of Virtual Assets With an Eye to Emerging Technologies

On October 28, 2021, the Financial Action Task Force (FATF), the international body that sets standards for anti-money laundering and countering the financing of terrorism (AML/CFT), released updated guidance addressing the...more

US Treasury Provides Detailed Guidance for the Virtual Currency Industry on Sanctions Compliance

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued detailed guidance to the virtual currency industry, putting virtual currency companies on notice of the ways OFAC...more

US Department of the Treasury Publishes Sanctions Review Results

On October 18, 2021, the U.S. Department of the Treasury released the results of its broad review of economic and financial sanctions. The review, initiated by the Biden administration, included discussions with Congress,...more

FINRA Issues Guidance Encouraging Firms To Prepare for Forthcoming Anti-Money Laundering Rules

On October 8, 2021, the Financial Industry Regulatory Authority (FINRA) issued a Regulatory Notice urging its member firms (i.e., broker-dealers) to consider how they will incorporate the U.S. Treasury Department’s...more

Cryptocurrency Regulation and Enforcement at the US Federal and State Levels

In recent months, the increased focus on cryptocurrency regulation and enforcement at both the federal and state levels demonstrates the digital currency’s place as an established component of the financial landscape. At the...more

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts - August 2021

This issue discusses a variety of legal, regulatory and enforcement developments in the digital asset space in the U.S. and Europe, including expanded reporting requirements for broadly defined cryptocurrency “brokers,” a...more

FinCEN Sets Out Anti-Money Laundering Priorities, With Implementing Regulations To Follow

On June 30, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first government-wide priorities (Priorities) for combatting money laundering and the financing of terrorism.1...more

US Amends Sanctions Targeting Investments in Securities of Chinese Companies

On June 3, 2021, President Joe Biden issued Executive Order 14032 (EO 14032) amending and, in effect, recasting Executive Order 13959 of November 12, 2020 (EO 13959), which restricted U.S. persons from purchasing and selling...more

Sanctions Remain Key; Implementation of Sweeping Anti-Money Laundering Legislation Begins

Sanctions - The Biden administration has made clear that economic sanctions will continue to be an important U.S. foreign policy tool and has initiated a comprehensive review of current sanctions policies and practices....more

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