Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities -
SUMMARY -
On April 24, 2024, President Biden signed into law a foreign military...more
5/8/2024
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Due Diligence ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Sanction Violations ,
Self-Disclosure Requirements ,
Statute of Limitations ,
Trading with the Enemy Act ,
Voluntary Disclosure
As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more
12/23/2020
/ Anti-Money Laundering ,
Civil Monetary Penalty ,
Currency Transaction Reports (CTR) ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
FinCEN ,
Internal Revenue Code (IRC) ,
Limited Liability Company (LLC) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities Exchange Act ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury ,
Whistleblowers
Recent Enforcement Actions and Guidance from DOJ, FinCEN, and OFAC Demonstrate the Increased Commitment — and Cooperation — of Federal Regulators to Police Digital Currencies, Including Their Use in Ransomware Attacks -
Amid...more
11/16/2020
/ Bitcoin ,
Cryptocurrency ,
Cyber Attacks ,
Department of Justice (DOJ) ,
Digital Assets ,
Digital Currency ,
Enforcement Actions ,
Enforcement Guidance ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Securities and Exchange Commission (SEC)
OFAC Provides Guidance on the Essential Components of a Risk-Based Sanctions Compliance Program -
On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued guidelines...more
5/6/2019
/ Audits ,
Bank Secrecy Act ,
Compliance ,
Economic Sanctions ,
Employee Training ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Risk Assessment ,
Sanction Violations ,
U.S. Treasury
This Enforcement Action Underscores The Risks Of Sourcing Products Without Comprehensive Supply Chain Due Diligence -
On January 31, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury...more
2/8/2019
/ China ,
Cosmetics ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Goods or Services ,
Imports ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Supply Chain