All Things Investigations: Episode 30 - The Convergence of ABC, AML and Export Controls with Mike Huneke and Jan Dunin-Wasowicz
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...more
On July 3, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had amended entries for a multitude of entities sanctioned under the Treasury’s Russian Harmful Foreign...more
The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...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. ...more
New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more
Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more
ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....more
With the current state of the world and heightened scrutiny of the nonprofit sector, it is critical that nongovernmental organizations (NGOs) with international reach routinely assess the effectiveness of their trade...more
Teradyne, a Massachusetts-based supplier of semiconductor testing equipment, has reportedly pulled $1 billion of manufacturing equipment out of China in 2023 following export controls on advanced computing materials and...more
On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more
Enforcement and legal risks relating to sanctions compliance remain high and all firms should continue to exercise care in meeting regulatory expectations. The promulgation of new sanctions relating to Russia has slowed but...more
The UK Financial Conduct Authority (FCA) has assessed the systems and controls relating to sanctions compliance for over 90 firms across a range of sectors and summarised its findings of good and poor practice. Acknowledging...more
Mike Huneke and Jan Dunin-Wasowicz join Tom Fox on this episode of All Things Investigation, to shed light on key ideas and challenges faced by companies and compliance professionals in the evolving landscape of trade...more
OFAC continues its enforcement push. At the same time, OFAC is managing a complex, global set of sanctions against Russia. DOJ has promised to increase prosecution of global banks for sanctions violations....more
The cryptocurrency industry has a target on its back – and perhaps justifiably so. The SEC, CFTC and OFAC have been bringing a number of regulatory enforcement actions, including against Bittrex, Inc. ($24,280,829.20 in...more
Privy Council rules against extension of the Quincecare duty - Does a bank owe a duty of care to a person who is the beneficial owner of funds held in the account of a customer of the bank and who has been defrauded by...more
With the Russian-Ukraine war’s ever-expanding sanctions landscape, the supply chain is even more complex than it already was, and enforcement risk is even higher given the broader array of U.S. federal and international...more
“Know your customer” is a bed rock principle of anti-money laundering and sanctions compliance programs, but it’s not always easy, particularly as more sophisticated and aggressive players have taken the field in recent...more
With Russia’s invasion of Ukraine last week, we saw a swift response by the U.S. beginning with President Biden’s Executive Order 14024 (“The EO”) and followed quickly by the Office of Foreign Assets Control’s (“OFAC”) severe...more
Recently, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury Department, released a report on ransomware trends stating that during the first half of 2021, 68 different ransomware variants...more
On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more
Earlier this year, the U.S. Government initiated a series of actions to address the People’s Republic of China’s continuing efforts to undermine the autonomy of the Special Administrative Region of Hong Kong (Hong Kong)....more
On July 27, 2020, the United Kingdom’s Office of Financial Sanctions Implementation (“OFSI”), the office in Her Majesty’s Treasury responsible for administering UK sanctions, released Maritime Guidance: Financial sanctions...more
How can a compliance professional navigate an increasingly complex sanctions landscape around a best practices sanctions compliance program and what happens if there is a compliance failure? I recently visited with Adam Frey,...more
AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more