News & Analysis as of

Office of Foreign Assets Control (OFAC) Banks

BakerHostetler

Weekly Blockchain Blog - September 2024

BakerHostetler on

Crypto Payments Firms Announce New Integrations and Initiatives - According to reports, fintech bank Revolut recently announced a partnership with Ledger, a major crypto hardware wallet provider, to make it easier for...more

Ballard Spahr LLP

Bank’s Digital Assets Business Strategy Draws Federal Reserve Scrutiny

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The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Issues Cease and Desist Order Against Banking-As-A-Service Provider

On June 14, the Federal Reserve Board (Fed) released a cease and desist order against an Arkansas-based banking-as-a-service (BaaS) provider for compliance and risk management failures. As part of the order, the bank is...more

The Volkov Law Group

OFAC Settles with Mondo TV for $538k for Violation of North Korean Sanctions

The Volkov Law Group on

OFAC has been busy and not so busy — what do I mean? OFAC is administering a complex set of coordinated sanctions against Russia, in close coordination with the EU and the UK....more

Ballard Spahr LLP

The American Front in Russia’s War on Ukraine: DOJ’s “Task Force KleptoCapture” Continues Focus on Operations of Sanctioned...

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We previously have blogged on actions taken by the DOJ’s “Task Force KleptoCapture,” an interagency law enforcement task force with a mandate to target sanctioned Russian and pro-Russian oligarchs. While explicitly launched...more

Williams Mullen

New Russia Sanctions Target Foreign Financial Institutions, Expand Import Bans

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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

Sheppard Mullin Richter & Hampton LLP

New Russia Sanctions Intensify Pressure on Banks Worldwide

On December 22, 2023, President Biden signed a new Executive Order (E.O. 14114) containing the latest round of sanctions against the Russian Federation. Shortly thereafter, Treasury Secretary Janet Yellen stated that the...more

The Volkov Law Group

OFAC Imposes Modest $31,867 Penalty on Emigrant Bank for Iran Sanctions Violations, Highlighting Value of Voluntary Disclosure

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Emigrant Bank (“Emigrant”), a U.S.-based financial institution that bills itself as the oldest bank in New York City, is the latest sanctions violator to be swept up in OFAC’s ongoing enforcement push. On September 21, OFAC...more

Wilson Sonsini Goodrich & Rosati

Considerations for M&A Transactions Involving Fintech Companies

M&A transactions involving financial services providers—including tech-based providers or “fintechs”—raise a host of unique questions based on the types of services they provide, which are often highly regulated and may...more

Orrick, Herrington & Sutcliffe LLP

National bank fined $98 million by OFAC, Fed for sanctions violations

On March 30, the U.S. Treasury Department’s Office of Foreign Assets (OFAC) announced a $30 million settlement with a national bank to resolve potential civil liabilities stemming from trade insourcing software that the bank...more

The Volkov Law Group

Wells Fargo Fumbles Sanctions Compliance Demonstrating An Absence of Culture of Compliance (Part II of II)

The Volkov Law Group on

Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...more

Lowenstein Sandler LLP

Silicon Valley Bank Fallout: Navigating and Managing the Account Opening Processes at Other Financial Institutions

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Silicon Valley Bank, Santa Clara, California, was closed on March 10 by the California Department of Financial Protection and Innovation (CDFPI). On March 12, the New York State Department of Financial Services (NYSDFS)...more

K2 Integrity

One Year Later Implementing Sanctions Against Russia

K2 Integrity on

Approximately one year ago, in the immediate wake of Russia’s full-scale invasion of Ukraine, the United States (U.S.), United Kingdom (UK), and European Union (EU) launched a global sanctions campaign against Russia that...more

Orrick, Herrington & Sutcliffe LLP

OFAC settles with Danish company for routing prohibited financial transactions though a U.S. bank

On December 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a more than $4.3 million settlement with a multinational Danish manufacturer to resolve allegations that its wholly owned United...more

Davis Wright Tremaine LLP

The Headwinds Facing Faster Payments

With Real-Time Payments from The Clearing House rapidly gaining traction among banks and FedNow set to launch next July, one might believe that adoption of instant payments among network participants and users will be smooth...more

Sheppard Mullin Richter & Hampton LLP

Myanmar Sanctions – A Last Resort Against a Non-Cooperating Country

On October 21, 2022, the Financial Action Task Force (FATF) officially moved Myanmar onto the agency’s blacklist, where it joins Iran and North Korea, the only other two listed countries. It is likely that the United States...more

The Volkov Law Group

OFAC Issues Notice of Violation Against Puerto Rico Bank But Imposes No Penalty for Sanctions Violations

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The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a finding of violation (“FoV”) to Nodus International Bank, Inc. (“Nodus”), located in Puerto Rico, for violation of Venezuelan Sanctions. Nordus...more

Fuerst Ittleman David & Joseph

D.C. Circuit: U.C.C. Article 4A Does Not Govern Judgment Creditors’ Claims to Sanctioned Company’s Funds Held by Intermediary...

On August 16, 2022, the United States Court of Appeals for the D.C. Circuit issued its ruling in Estate of Jeremy Isadore Levine, et al. v. Wells Fargo Bank, N.A., No. 21-7036, –F.4th– (D.C. Circuit August 16, 2022), a case...more

Cadwalader, Wickersham & Taft LLP

Lessons Learned from Recent OFAC Enforcement Actions

Two recent OFAC enforcement actions highlight real-world challenges that financial institutions and other companies may face in their efforts to implement an effective sanctions compliance program....more

Ballard Spahr LLP

FinCEN and BIS Issue Joint Alert on Potential Russian and Belarusian Export Control Evasion

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The Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a joint alert on June 28, 2022, warning of evasion attempts by individuals or entities to...more

Ballard Spahr LLP

OCC Highlights Risks Associated with Compliance Staffing Concerns, Russia Sanctions, Environmental Crimes, Cyber Attacks and...

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On June 23, 2022, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (SRP) for spring 2022. In the SRP, the OCC opines on its current safety and soundness concerns for banks under...more

Locke Lord LLP

OFAC Russia and Related Sanctions ‎Update

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On May 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) updated three FAQs (FAQ 1034, FAQ 1035, and FAQ 1038). Specifically, OFAC amended its guidance on the meaning of the terms...more

Perkins Coie

War in Ukraine Prompts Further Trade Sanctions by the United States

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Russia’s invasion into Ukraine in February 2022 has prompted the United States and its allies, including the United Kingdom, the European Union, and others, to issue substantial international trade restrictions such as...more

Wilson Sonsini Goodrich & Rosati

New U.S. Sanctions on Russian Banks and Elites, Expanded Export Controls, and Other Updates

The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC or the Treasury) unveiled a new wave of sanctions targeted against Russia, Russian entities, and Russian individuals during the week of April 4, in...more

K&L Gates LLP

New U.S. Sanctions Restrict Investment and Services in Russia and Block Major Russian Banks

K&L Gates LLP on

On 6 April 2022, the United States imposed a new round of sanctions on Russia in response to its continued actions in Ukraine. K&L Gates covered previous rounds of sanctions in alerts on 24 February, 25 February, 15 March,...more

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