Last week, the Office of Foreign Assets Control (OFAC) announced an interim final rule which amends the recordkeeping and reporting requirements relating to the various economic sanctions programs it enforces. Notably, the...more
As lawyers, corporate executives and federal law enforcement officials prepare to gather this week in San Francisco for the ABA’s 39th National Institute on White Collar Crime, we offer our takeaways from January’s Houston...more
3/5/2024
/ Anti-Corruption ,
Cannabis Products ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement ,
Environmental Social & Governance (ESG) ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
Investment ,
Market Manipulation ,
Office of Foreign Assets Control (OFAC) ,
San Francisco ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes ,
Wire Fraud
2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more
1/12/2024
/ Bureau of Industry and Security (BIS) ,
CFTC ,
Compliance ,
Economic Sanctions ,
Enforcement ,
European Anti-Fraud Office (OLAF) ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
Suspicious Activity Reports (SARs) ,
Voluntary Disclosure ,
Whistleblowers
A recent OFAC enforcement action against MidFirst Bank highlights the five essential components of an effective sanctions compliance program that will serve to mitigate exposure in the event of a violation:
Senior...more
At a sanctions conference held in Washington D.C. on May 5, government officials, practitioners and corporations highlighted the government’s broadening focus on anti-corruption enforcement, across more traditionally siloed...more
5/17/2022
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Arms Export Control Act ,
Cryptocurrency ,
Cybersecurity ,
Economic Sanctions ,
Enforcement ,
Environmental Social & Governance (ESG) ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
ITAR ,
New Regulations ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Russia ,
Ukraine
“Know your customer” is a bed rock principle of anti-money laundering and sanctions compliance programs, but it’s not always easy, particularly as more sophisticated and aggressive players have taken the field in recent...more
3/16/2022
/ Anti-Money Laundering ,
Biden Administration ,
Compliance ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Executive Orders ,
FinTech ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Shell Corporations ,
U.S. Commerce Department ,
U.S. Treasury ,
Ukraine
Over the past week, the Biden Administration has announced unprecedented sanctions and export controls against Russia in response to its unprovoked invasion of Ukraine. As the State Department pledges an additional $350...more
In keeping with the United States government’s expanding scrutiny of cryptocurrency markets, the DOJ recently announced the creation of a National Cryptocurrency Enforcement Team (the “NCET”). The NCET endeavors to add a...more
10/27/2021
/ Anti-Money Laundering ,
CFTC ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury ,
Virtual Currency
On Friday, OFAC published a compliance guide aimed at the virtual currency industry, which promotes sanctions compliance amid the rise of ransomware attacks. Similar to OFAC’s recent advisory, this compliance guide is yet...more
On Tuesday, the U.S. Department of Treasury’s Office of Foreign Asset Control (“OFAC”) issued an updated advisory warning all ransomware victims that if they succumb to ransomware demands and pay foreign actors who are...more
9/24/2021
/ Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
FBI ,
Guidance Update ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Sanctions ,
SDN List ,
Strict Liability ,
U.S. Treasury
On June 3, 2021, the White House issued a memorandum announcing anti-corruption as a core national security interest. The memorandum explains that, “[c]orruption threatens United States national security, economic equity,...more
6/10/2021
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Biden Administration ,
China ,
Corporate Transparency Act ,
Cybersecurity ,
Economic Sanctions ,
Enforcement ,
Enforcement Actions ,
Export Controls ,
Foreign Agents Registration Act (FARA) ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities and Exchange Commission (SEC)