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
“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
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