FINCast Ep. 19 - The DPRK Sanctions Program
On June 27, 2024, Switzerland and the United States executed the Agreement between Switzerland and the United States of America to Improve International Tax Compliance and to Implement FATCA (New IGA), which will take effect...more
January 29, 2024- The U.S. Department of the Treasury issued a finding and notice of proposed rulemaking (NPRM) that identifies an Iraqi bank that serves as a conduit for terrorist financing, as a foreign financial...more
On December 22, 2023, President Biden issued Executive Order (EO) 14114, imposing significant new economic sanctions against Russia to address the ongoing national security threat posed by the country’s invasion of Ukraine...more
On December 22, 2023, President Biden issued new Executive Order (“EO”) 14114, amending EO 14024 and EO 14068. The new EO grants the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) authority to...more
On December 22, 2023, President Biden issued a new Russia-related Executive Order (“EO”) targeting foreign financial institutions (“FFIs”) that support Russia’s military-industrial base. The new EO allows the U.S. government...more
On December 22, 2023, President Biden signed Executive Order 14114, titled “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities” (EO 14114), with a focus on holding foreign financial...more
Over a year has now passed since Russia invaded Ukraine, and the U.S., the EU and its member states, the U.K., and many others—including Japan, Australia, New Zealand, Taiwan and Canada—continue to exert pressure on Russia...more
Le 17 février 2023, le gouvernement fédéral a publié un projet de règlements modificatifs (les « Règlements modificatifs ») modifiant certains règlements (les « Règlements ») pris en vertu de la Loi sur le recyclage des...more
On February 17, 2023, the federal government released draft amending regulations (Amending Regulations) to the regulations (Regulations) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and...more
Bajo el concepto de “FATCA recíproca”, las instituciones financieras y los corredores deben comenzar a prepararse para asumir mayores y más amplias responsabilidades de reportaje. Como partes interesadas de FATCA, las...more
The Financial Crimes Enforcement Network (“FinCEN”) has been busy during the last few weeks – and presumably will remain busy for the rest of 2021, as it attempts to satisfy numerous mandates imposed by the Anti-Money...more
OECD Guide Offers Financial Institutions Advice on Hiring External Service Organizations to Handle Compliance - While financial institutions (FIs) have final responsibility for compliance with the Foreign Account Tax...more
President Trump signs law authorizing sanctions on individuals and financial institutions and ends U.S. preferential treatment for Hong Kong. The Hong Kong Autonomy Act authorizes sanctions on foreign financial...more
On October 25, 2019, FinCEN issued a final rule imposing the Fifth Special Measure against the Islamic Republic of Iran as a “jurisdiction of primary money laundering concern” (“Final Rule”) under Section 311 of the USA...more
Leaders of FinCEN, CFTC and SEC Attempt an Intricate Dance of Competing Oversight of Virtual Currency - On October 11, the leaders of the Financial Crimes Enforcement Network (“FinCEN”), the Commodity Futures Trading...more
In the recent case of Lamesa Investments Ltd v Cynergy Bank Ltd [2019] EWHC 1877 (Comm), the High Court upheld the bank’s attempt to avoid a common banking dilemma: the ‘double jeopardy’ of being contractually liable to make...more
Further liberalisation of the Myanmar banking and financial services sector The Central Bank of Myanmar (“CBM”) is making significant strides towards opening up Myanmar’s banking and finance sector. In the past few months,...more
How should we approach competing sanctions risks? Among the numerous regulatory compliance risks faced by financial institutions, economic and trade sanctions risks commonly receive a great deal of attention....more
While major enforcement actions against foreign banks for U.S. sanctions violations appear to have ebbed over the past three years, the recent settlement of sanctions-related claims, which included imposition of $1.34 billion...more
On December 13, 2018, U.S. Department of the Treasury and the Internal Revenue Service released proposed regulations (the “Proposed Regulations”) that would amend the current regulations relating to the Foreign Account Tax...more
NYDFS Action Highlights the Need for Good Monitoring – and Good Consultants - In part one of this two-part post, we provided some practical tips for financial institutions to increase the chances that their Anti-Money...more
Withdrawal from the Iran nuclear agreement triggers full implementation of US sanctions, including threat of “secondary” sanctions on non-US persons dealing with Iran. As reported in the Latham Client Alert dated May 10,...more
Automatic exchange of information (AEOI) regimes, primarily aimed at curbing tax avoidance through the use of foreign accounts and investment platforms, have recently become a global trend, starting with the adoption of the...more
On August 30, 2016, the U.S. Department of the Treasury and four U.S. federal banking regulators sought to correct a problem—at least in part one of their own creation—by issuing a “Joint Fact Sheet on Foreign Correspondent...more
Global tax evasion remains a major problem for governments around the world. At a time when virtually all of the governments from the world’s major economies seek additional revenue, the attractiveness to taxpayers of...more