News & Analysis as of

Office of Foreign Assets Control FinCEN

Red Notice Newsletter - October 2017

ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more

Anti-Money Laundering and Bank Secrecy Act Update

by Moore & Van Allen PLLC on

After the Panama Papers exposed efforts by wealthy individuals and government officials to hide funds offshore, government authorities around the world have responded with new legislation, regulations and enforcement actions...more

US Persons and Financial Institutions: Beware when engaging financially with Venezuela

by Foodman CPAs & Advisors on

On 8/25/17, President Donald Trump signed an Executive Order (EO) restricting and prohibiting certain transactions between US Persons and Venezuela. The transactions that are prohibited by US Persons apply wherever a US...more

FinCEN Warns U.S. Financial Institutions Of Venezuelan Money Laundering Threat

by Fox Rothschild LLP on

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued an advisory to alert financial institutions of widespread public corruption in Venezuela and the methods Venezuelan senior political figures...more

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations - On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation...more

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations - On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation...more

May, June and July Developments

by Sullivan & Worcester on

With a straight face, President Trump has issued an executive order on June 20th that would expand Apprenticeship opportunities in the US in order to expand jobs. The CFTC has adopted some final rules on records...more

Red Notice Newsletter - July 2017

ANTICORRUPTION DEVELOPMENTS - U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations - On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation...more

Red Notice Newsletter - March 2017

Anticorruption Developments - SEC Chairman Nominee Jay Clayton Receives Confirmation Hearing - On March 23, 2017, SEC Chairman Nominee Jay Clayton testified before the Senate Banking Committee at his confirmation...more

International AML Enforcement in 2017 Expected to Target Consumer-Due-Diligence Programs, Gaming Entities, Prepaid Cards, Digital...

by K&L Gates LLP on

Over the past two years, financial regulatory bodies in the United States and Europe have increasingly emphasized consumer due diligence (“CDD”) by financial institutions as a means to combat money laundering and terrorist...more

Digital Currency Exchange Customers Targeted in IRS Information-Gathering Sweep

by BakerHostetler on

Coinbase, one of the largest digital currency exchange companies in the world, will likely be asked to provide the Internal Revenue Service (IRS) with transactional data and other information on all U.S. customers who used...more

Sanctions Roundup: Third Quarter 2016 and Executive Order on Burmese Sanctions

by Shearman & Sterling LLP on

OFAC, acting under the direction of President Obama’s Executive Orders, has lifted the economic and financial sanctions against Burma and Côte D’Ivoire. The revisions open these countries, and their financial markets, to...more

Lifting of Myanmar sanctions

by DLA Piper on

On October 7, 2016, U.S. President Barack Obama issued an executive order lifting U.S. sanctions against Myanmar (also known as Burma) imposed under earlier executive orders and setting aside other statutory blocking and...more

US Terminates Burma Sanctions Program, Accompanied by Limited FinCEN Relief

by White & Case LLP on

On October 7, 2016, President Obama signed an Executive Order terminating the national emergency with respect to Burma (Myanmar), revoking the Burma sanctions Executive Orders, and waiving other statutory blocking and...more

After Nearly 20 Years, US Lifts Burma Sanctions

After nearly two decades, the United States has formally ended economic sanctions on Burma (Myanmar). Citing substantial efforts undertaken to promote democracy, President Barack Obama issued an executive order, on October 7,...more

Why is On-boarding and Off-boarding Bank Clients Important?

by Foodman CPAs & Advisors on

After the Panama Papers, and with the recent FinCEN final Customer Due Diligence (CDD) rule, U.S. financial institutions are further focused on tightening internal controls against money laundering, terrorist financing,...more

Are You Within Reach of Anti-Money Laundering Enforcement? The Tentacles of Money Laundering Schemes Affect Real Estate Investors...

The U.S. Treasury Department has signaled the latest focus of its enforcement: real estate ventures with ties to money laundering schemes. Individual real estate investors and companies involved in luxury real estate, real...more

FinCEN Issues Customer Due Diligence Rules and Amends AML Program Rules

by Ropes & Gray LLP on

On May 11, 2016, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a final rules release (the “Release”) containing new rules to strengthen customer due diligence (“CDD”) requirements for...more

North Korea Designation Targets Chinese Banks (IRB No. 554)

by Bryan Cave on

On May 25, the U.S. Treasury Department issued a finding designating North Korea as a jurisdiction of “primary money laundering concern.” On the same date, Treasury, through FinCEN, issued a notice of proposed rulemaking...more

Addressing AML Risks in the Era of Aggressive Enforcement

by Michael Volkov on

The resurgence in anti-money laundering enforcement in the last few years reflects the overall improvement in the banking industry and recovery from the financial collapse. Federal prosecutors and regulators have renewed...more

Panama Papers Fallout: A Push for Transparency and Regulatory Reform - Sanctions Also Levied Against Several Panama-Based...

by Holland & Knight LLP on

In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

"FinCEN Finalizes Customer Due Diligence Rule Amid Other Actions to Enhance Financial Transparency"

In the wake of the Panama Papers controversy, the U.S. government has taken major steps this month to promote financial transparency. First, the Financial Crimes Enforcement Network (FinCEN) finalized its proposed rule issued...more

Tackling a Panamanian Money Laundering Organization: OFAC Sanctions the Waked Money Laundering Organization, Colombia Arrests the...

OFAC Sanctions - On May 5, 2016, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) announced sanctions against 77 entities and individuals associated with the Waked Money Laundering Organization...more

Red Notice Newsletter - March 2016

ANTICORRUPTION DEVELOPMENTS – Olympus to Pay $646 Million for Anti­Kickback and FCPA Violations - Early this month, Olympus Corp. of the Americas (OCA) settled government investigations related to violations of the...more

Enhanced North Korea Sanctions Adopted

by WilmerHale on

The United Nations Security Council (“UNSC”) approved a Resolution last week imposing new sanctions against North Korea in response to its recent nuclear and missile tests. This UNSC action follows the enactment of the North...more

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