News & Analysis as of

Evasion

Venable LLP

OFAC Issues Sanctions Compliance Guidance and Scenarios for U.S. and International Maritime Industry

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On October 31, 2024, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued scenario-based guidance specific to the maritime shipping industry....more

Baker Botts L.L.P.

Enhancing Compliance in the Maritime Shipping Industry

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Today, the US Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued an OFAC Compliance Communiqué: Sanctions Compliance Guidance for the Maritime Shipping Industry designed to aid maritime sector...more

Locke Lord LLP

Price Cap Coalition Issues Advisory ‎Regarding Sanctions Evasion Techniques by the Shadow ‎Fleet

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On October 21, 2024, the Price Cap Coalition—comprising the G7, European Union, Australia, and New Zealand—released an updated advisory to address the rising risks of price cap evasion associated with the maritime oil trade,...more

K&L Gates LLP

Top Tips for Sanctions Compliance and Preventing Sanctions Evasion

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On 24 September 2024, the G7 released updated guidance on the prevention of evasion of export controls and sanctions imposed on Russia. The aim of the guidance is to “assist industry in identifying Russian evasion practices...more

McDermott Will & Emery

Quarterly Sanctions Update | Q3 2024

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Although the European Union and the United Kingdom did not introduce new sanctions against Russia over the summer, they extensively focused on the implementation of the existing measures and their enforcement. This week,...more

Ankura

Russian Sanctions Circumvention: Are You Asleep At The Wheel?

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In the wake of Russia's invasion of Ukraine in February 2022, a broad and unprecedented range of sanctions were imposed on Russia by various countries and international bodies to target the Russian economy and prevent further...more

ArentFox Schiff

Investigations Newsletter: Former Congressman George Santos Pleads Guilty to Wire Fraud and Aggravated Identity Theft

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Former Congressman George Santos Pleads Guilty to Wire Fraud and Aggravated Identity Theft - On August 19, former US Representative George Santos pleaded guilty to wire fraud and aggravated identity theft. As part of the...more

WilmerHale

Asset freezing and asset seizing under the UK sanctions regime

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The UK’s National Crime Agency (NCA) recently secured its first forfeiture of sanctioned funds. This was a landmark achievement for the NCA’s Combatting Kleptocracy Cell, which has only existed since 2022 and aims to...more

BakerHostetler

Deeper Dive: Understanding the 2023-24 Crypto Threat Landscape

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As the Web3 and digital assets ecosystem continues to grow, hacks, scams and other threats remain a major cause for concern and a potential impediment to broader adoption. Data from various sources indicates that after a year...more

Holland & Knight LLP

OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

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Nearly six months after President Joe Biden signed an executive order (EO) authorizing secondary sanctions against Foreign Financial Institutions (FFIs) conducting or facilitating significant transactions with certain...more

BakerHostetler

Weekly Blockchain Blog - May 2024

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Fintech and Crypto Firms Announce New Cryptocurrency Products - According to recent reports, a major U.S. fintech firm will begin letting its users accept payments in USDC. ...more

Torres Trade Law, PLLC

CBP Publishes EAPA Final Rule and Launches AD/CVD Evasion Statistics Tool

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March 2024 was a busy month for U.S. Customs and Border Protection (“CBP” or “Customs”) with respect to the Enforce and Protect Act (“EAPA”) regulations related to the evasion of antidumping and countervailing duties...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - March 2024 #2

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In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

American Conference Institute (ACI)

Sanctions Compliance Measures to Mitigate Russia Trade Sanctions Evasion Tactics

The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more

K2 Integrity

[Webinar] Mitigating Risks of Russian Trade Control Evasion - December 13th, 7:00 am PT

K2 Integrity on

Join our panel of experts for a one-hour conversation about the pressing issues surrounding the transshipment of restricted tools and technologies, with a particular focus on mitigating the risk of these products ending up in...more

Foodman CPAs & Advisors

Control De Exportaciones: Señales De Alerta De FinCEN

Foodman CPAs & Advisors on

El 6/11/23, la Oficina de Industria y Seguridad (“BIS” o “Bureau of Industry and Security”) del Departamento de Comercio y FinCEN emitieron un Aviso Conjunto sobre la evasión del control de exportaciones destacando un nuevo...more

Foodman CPAs & Advisors

Export Control FinCEN Red Flags

Foodman CPAs & Advisors on

On 11/6/23, the Department of Commerce’s Bureau of Industry and Security (BIS) and FinCEN issued a joint notice regarding export control evasion highlighting a new Suspicious Activity Report key term (“FIN-2023-GLOBALEXPORT”)...more

Paul Hastings LLP

First-of-its-Kind E5 Joint Guidance Prioritizes Industry Compliance to Prevent Diversion of Items Critical to Russian Weapons...

Paul Hastings LLP on

On September 26, 2023, the “Export Enforcement Five” or “E5” partnership among the governments of Australia, Canada, New Zealand, the United Kingdom, and the United States issued joint guidance focused on preventing Russian...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - July 2023

Lowenstein Sandler LLP on

On June 16, the U.S. Department of Commerce published a final rule, to be effective July 17, implementing the Protecting Americans’ Sensitive Data From Foreign Adversaries and amending the Securing the Information and...more

Eversheds Sutherland (US) LLP

Russia sanctions update - June 2023

On May 19, 2023, the Biden Administration along with leaders of the Group of Seven (G7), unveiled a new package of sanctions. The G7 leaders released a joint statement reaffirming their commitment to offer “the financial,...more

Goodwin

FinCEN and the U.S. Department of Commerce’s BIS Issues Supplemental Alert Urging Continued Vigilance for Potential Russian Export...

Goodwin on

On May 19, FinCEN and BIS issued an alert urging financial institutions to watch for attempts to evade export controls imposed on Russia. The alert focuses on ongoing federal initiatives to limit Russian access to technology...more

Orrick, Herrington & Sutcliffe LLP

FinCEN and Commerce Dept. urge monitoring of Russian export control evasion attempts

On May 19, FinCEN and the Department of Commerce’s Bureau of Industry and Security (BIS) issued a supplemental joint alert urging continued vigilance for potential Russian export control evasion attempts...more

Ankura

Preventing the Use of Cryptocurrencies to Evade Sanctions

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Cryptocurrencies have been making the headlines for all the wrong reasons. Their values have plummeted leaving investors out of pocket. Exchanges, lenders, and other entities in the crypto ecosystem have gone bust. Numerous...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Congress Fixes Major Hole In Treasury’s Nascent Whistleblower Program While Expanding Its Scope To Sanctions Evaders

Takeaways: •The Treasury Whistleblower Program now provides for guaranteed awards of 10% to 30% of the government recovery in covered actions- •The Treasury Whistleblower Program has been expanded to include not just tips...more

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