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OFAC Amends Cuba Sanctions, Loosening Restrictions and Fully Implementing Biden Administration’s Cuba Policy

On May 28, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced amendments to 31 C.F.R. Part 515, the Cuban Assets Control Regulations (CACR), expanding access to certain financial and...more

Hiding in Plain Sight: New Ukraine and Israel Aid Package Includes Significant Changes to US Sanctions and Export Control Laws

On April 24, 2024, President Biden signed into law H.R. 815, an emergency appropriations package billed as authorizing $95 billion in foreign aid to Ukraine and Israel (the Act). While the Ukraine and Israel aid provisions...more

Enhanced Global Russian Sanctions and Export Controls to Counter Circumvention

On May 19, in response to Russia’s ongoing invasion of Ukraine, the United States, in coordination with allies and partners, announced new sanctions restrictions and export controls targeting Russia’s evasion networks,...more

A Look At The Feds' Extraordinary Reaction To SVB Collapse

On Sunday evening, the U.S. Department of the Treasury, Federal Reserve, and the Federal Deposit Insurance Corporation announced measures to (1) prevent losses to all depositors — including all uninsured depositors — after...more

FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more

Biden to Federal Government: Assess Financial Risk of Climate Change

On May 20, President Biden issued his Executive Order on Climate-Related Financial Risk (“Order”) which requires federal agencies to assess the potential impacts of climate change on public and private financial institutions...more

President Biden Signs New Executive Order Escalating US Sanctions Against Russia

On April 15, 2021, President Biden signed a new executive order, Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation, escalating US sanctions against the Russian...more

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