The US Treasury Department has released its 2021 Sanctions Review (the “Review”), which describes the US sanctions framework and the agency’s future sanctions priorities. The Review reflects on the evolution over two decades...more
10/20/2021
/ China ,
Corporate Counsel ,
Economic Sanctions ,
EU ,
Hong Kong ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Public Policy ,
Russia ,
U.S. Treasury ,
Venezuela ,
Virtual Currency
A new rule effective March 22, 2021 establishes a process for the US Department of Commerce to review commercial transactions between US and foreign parties for certain information and communications technology and services...more
3/23/2021
/ Biden Administration ,
China ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Cross-Border ,
Cuba ,
Foreign Adversaries ,
Hong Kong ,
Interim Final Rules (IFR) ,
Iran ,
Licensing Rules ,
National Security ,
North Korea ,
Russia ,
Safe Harbors ,
Supply Chain ,
Technology ,
Telecommunications ,
U.S. Commerce Department ,
Venezuela
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more
7/29/2019
/ Anti-Money Laundering ,
BSA/AML ,
Cuba ,
Customer Due Diligence (CDD) ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
FinCEN ,
Human Trafficking ,
Iran ,
Magnitsky Act ,
Nicaragua ,
North Korea ,
Russia ,
Sudan ,
Trump Administration ,
Venezuela ,
Virtual Currency
On November 28, the Treasury Department sanctioned two Iran-based individuals for exchanging bitcoin into Iranian rials on behalf of malicious cyber actors involved in the SamSam ransomware scheme. Notably, this action marks...more
12/3/2018
/ Bitcoin ,
Crypto Exchanges ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Iran ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
SDN List ,
U.S. Treasury
On November 5, 2018, the United States took steps to complete the U.S. withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”), under which the United States – along with its partners in the P5+1 – had previously...more
11/9/2018
/ Blocked Entities ,
Economic Sanctions ,
EU ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
P5+1 Nations ,
SDN List ,
Trump Administration ,
UN Security Council
President Donald Trump issued an Executive Order “Reimposing Certain Sanctions with Respect to Iran” (“New Iran E.O.”) on August 6, 2018, authorizing the re-imposition – or “snap-back” – of various sanctions against dealings...more
On Friday, May 18, the EU Commission launched the formal process to reactivate a 1996 trade defense law in response to the US withdrawal from the Joint Comprehensive Plan of Action (JCPOA) on Iran's nuclear program. Once...more
5/23/2018
/ Blocking Statutes ,
China ,
EU ,
European Commission ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Russia ,
Trade Relations ,
Trump Administration
On Tuesday, May 8, President Trump announced that the United States would end its participation in the Joint Comprehensive Plan of Action (JCPOA), signed by the Permanent Five Members of the Security Council plus Germany...more
On July 27, the US Senate passed the Countering America's Adversaries Through Sanctions Act (CAATSA), a comprehensive sanctions bill that expands US sanctions against three countries: Russia, Iran, and North Korea. The...more
Over the past year, regulators continued to actively examine compliance, introduce new and heightened requirements, recalibrate global priorities, and aggressively pursue enforcement. This report reviews recent trends and...more
4/28/2017
/ BSA/AML ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
FATF ,
Financial Services Committee ,
FinCEN ,
Iran ,
NYDFS ,
Russia ,
Securities and Exchange Commission (SEC)
On April 18, 2017, the State Department certified to Congress that Iran was in compliance with its obligations under the Joint Comprehensive Plan of Action (JCPOA) between the United States, Iran, and the P5+1 nations. It...more
On January 16, 2016, the United States, its negotiating partners and Iran announced the arrival of Implementation Day for the Joint Comprehensive Plan of Action (JCPOA), to which the parties agreed on July 14, 2015 with...more
On July 14, 2015, the United States and its P5+1 negotiating partners, together with Iran, announced the final terms of the Joint Comprehensive Plan of Action (JCPOA) concerning Iran’s nuclear program. The JCPOA is designed...more
7/16/2015
/ Banking Sector ,
Energy Sector ,
Financial Institutions ,
Foreign Relations ,
IAEA ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
P5+1 Nations ,
Trade Relations ,
UN Security Council ,
United Nations
Yesterday, the Senate Foreign Relations Committee unanimously passed legislation that would allow Congress to review—and potentially block—any final deal reached with Iran over its nuclear program. The Iran Nuclear Agreement...more
On April 2, 2015, the United States and its P5+1 negotiating partners, together with Iran, announced the key parameters of the Joint Comprehensive Plan of Action (JCPOA) regarding Iran’s nuclear program. Further details are...more