Episode 302 -- Matt Stankiewicz on DOJ's Massive Criminal Settlement with Cryptocurrency Exchange Binance and its CEO Changpeng Zhao
Polsinelli Podcast - An International Trade Issue That May Impact Your Business
Compliance with sanctions regimes has been a priority for debt markets. Amid rising geopolitical tensions, the stakes for lenders and borrowers are higher than ever - Intensifying geopolitical tensions and the US...more
Effective April 24, the statute of limitations (“SoL”) under the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) has been extended from five to ten years. It would have been...more
Miami, Florida, U.S.A.- Estlund Law client Dr. Faezeh Faghihi has spent her life in the service of others as a physician in her native Iran and in the United States, her adopted home country. Trained as a gynecologist, she...more
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on August 8, 2022, imposed sanctions against the popular decentralized virtual currency mixer Tornado Cash alleging that it has been used to launder...more
The Second Circuit last week in United States v. Halkbank significantly limited the immunity granted under the Foreign Sovereign Immunities Act (FSIA) by giving a broad interpretation to the act’s “commercial activity”...more
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several actions focused on disrupting criminal digital finance infrastructure, including virtual currency...more
The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” This advisory continues prior advisory...more
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory outlining the risks involved with facilitating ransom payments to malicious actors conducting...more
On October 30, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published an advisory highlighting potential sanctions risks arising from dealings in “high-value artwork” (with “particular...more
On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an advisory regarding potential sanctions risks related to facilitating ransomware payments... OFAC is the federal...more
This past weekend saw a halt to the anticipated September 20 implementation of broad prohibitions published on September 18 by the U.S. Department of Commerce (Commerce) regarding TikTok and WeChat mobile applications. No...more
On September 18, 2020, the U.S. Department of Commerce issued two orders identifying the specific transactions related to the WeChat and TikTok mobile applications ("Orders") that are prohibited pursuant to Executive Orders...more
As the countdown continues to September 20, our International Trade & Regulatory Group examines the ambiguities underlying the unprecedented Executive Orders purporting to ban the use of TikTok and WeChat, questions that may...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 June 29, dual trial verdicts in the Southern District of New York paved the way for the government to seize 650 Fifth Avenue, a 36-story building in Manhattan valued at up to $1 billion (“the Property”). The defendants,...more
On February 10, 2017, the U.S. Treasury Department announced an increase in civil monetary penalties across a number of Treasury offices, including the Office of Foreign Assets Control (OFAC). Understanding the potential...more
How easily can the Trump administration change the status quo? The International Emergency Economic Powers Act (IEEPA), 50 U.S.C §§1701-1707 enacted October 28, 1977, authorizes the US president to broadly regulate...more
On April 1st of last year, President Obama, by Executive Order 13694, declared a national emergency pursuant to the International Emergency Economic Powers Act to “deal with the unusual and extraordinary threat to the...more
Increased anti-money laundering (AML) regulation enforcement by federal and state agencies in recent months should have financial institutions across the country reviewing and strengthening their in-house AML policies and...more
There is a key new development for US companies and individuals dealing in international markets. The Obama Administration issued a new Executive Order that will subject certain individuals and entities engaging in so-called...more
In response to the growing cyber security threats from outside of the United States, the U.S. Government has added an entire new category of sanctioned individuals and organizations to its list of Specially Designated...more
The U.S. Government announced two major sanctions enforcement actions this week that reinforce the compliance challenges faced by both U.S. companies with international activities and non-U.S. companies subject to U.S....more
With the imposition of billion-dollar fines against large financial institutions, the U.S. Department of Justice ("DOJ") is focusing on banks for not only failing to comply with federal laws, but also for willfully violating...more
On June 30, 2014, BNP Paribas SA (“BNPP”), the largest bank in France, pled guilty to conspiring to violate U.S. sanctions laws and agreed to pay a total of nearly $8.9 billion in criminal forfeiture and penalties to the U.S....more
HSBC Holdings, London, and two of its U.S. subsidiaries have been ordered to pay a record $1.92 billion in fines and penalties for anti-money laundering (AML) and Office of Foreign Assets Control (OFAC) violations....more