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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
A well-known digital currency investment services company announced the launch of its first European exchange-traded fund (ETF), according to a press release this week. The ETF, which will be traded on multiple foreign...more
A major U.S. fintech firm recently announced the launch of a “crypto payouts” pilot that will allow a select group of creators to receive cryptocurrency payments through a major social media platform. According to a press...more
ACI’s Annual Flagship Conference on Economic Sanctions Enforcement and Compliance is widely regarded as the premier conference designed for those working in global sanctions compliance, internal audits and investigations,...more
In another action targeting Russian actors and connections, the Justice Department indicted Elena Branson, a dual United States-Russian national with criminal evasion of Foreign Agents Registration Act (“FARA”) registration...more
The recent comprehensive economic sanctions by the U.S. and other nations against Russia has propelled the crypto community onto the geo-political stage in a major way. As with other forms of payment and methods of money...more