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
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
10/14/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
UK ,
Ukraine
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
9/29/2022
/ Biden Administration ,
Blockchain ,
Criminal Investigations ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Financial Regulatory Agencies ,
Non-Fungible Tokens (NFTs) ,
Popular ,
U.S. Treasury
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
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
5/2/2022
/ Blocking Sanctions ,
Economic Sanctions ,
EU ,
European Commission ,
Export Controls ,
Exports ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
UK
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
3/25/2022
/ Asset Freeze ,
Belarus ,
Blocking Sanctions ,
Economic Sanctions ,
EU ,
European Commission ,
Export Controls ,
Russia ,
Tariffs ,
UK ,
Ukraine
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
3/22/2022
/ Bank Notes ,
Banks ,
Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Financial Institutions ,
Luxury Goods ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
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
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
3/10/2022
/ Belarus ,
Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
Financial Institutions ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SWIFT ,
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
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
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
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
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
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
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
11/17/2021
/ AML/CFT ,
Bank Holding Company Act ,
Banking Regulators ,
Biden Administration ,
CFTC ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
FDIC ,
Financial Institutions ,
FinCEN ,
FinTech ,
OCC ,
Stablecoins ,
Virtual Currency ,
Working Groups
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
11/12/2021
/ AML/CFT ,
Central Bank Digital Currency (CBDCs) ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Digital Currency ,
FATF ,
Financial Institutions ,
FinTech ,
Guidance Update ,
Non-Fungible Tokens (NFTs) ,
Peer-to-Peer ,
Stablecoins ,
Virtual Currency
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
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
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
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
10/1/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BitMEX ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Digital Assets ,
Digital Currency ,
FinCEN ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
IRS ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Reporting Requirements ,
Securities and Exchange Commission (SEC)
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
8/27/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BitMEX ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Distributed Ledger Technology (DLT) ,
Enforcement Actions ,
FinCEN ,
Popular ,
Reporting Requirements ,
Smart Contracts
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
7/22/2021
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Financial Institutions ,
FinCEN ,
Human Trafficking ,
Internal Controls ,
National Security ,
Terrorist Financing ,
Terrorist Financing Regulations
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 -
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