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Office of Foreign Assets Control (OFAC) Enforcement Actions

Carlton Fields

Recent SEC AML Enforcement Actions and Likely Continued AML Emphasis Under New Administration

Carlton Fields on

Registered investment advisers have until January 1, 2026, to comply with the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). However, the SEC has recently charged two investment advisers with...more

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2024 Lessons Learned and 2025 Expectations

As the third month of the second Trump administration comes to a close, the lack of any public enforcement action by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctions watchers...more

Venable LLP

A Legal Whirlwind Settles: Treasury Lifts Sanctions on Tornado Cash

Venable LLP on

On March 21, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) officially lifted sanctions on Tornado Cash, the decentralized cryptocurrency mixer it had blacklisted in August 2022....more

Troutman Pepper Locke

Navigating 2025: Trends in OFAC and DOJ Enforcement for Digital Assets — The Crypto Exchange Podcast

Troutman Pepper Locke on

In this episode of Crypto Exchange, host Ethan Ostroff is joined by his colleagues Pete Jeydel and Peter Leary to discuss trends and lessons learned from recent civil enforcement actions by the Treasury Department's Office of...more

BakerHostetler

Weekly Blockchain Blog - April 2025

BakerHostetler on

U.S. Financial Services Firms Announce Digital Asset Initiatives - A major U.S. financial services company and operator of global financial exchanges and clearinghouses recently announced an agreement with the issuer of the...more

Paul Hastings LLP

New US Sanctions and Ongoing OFAC Designations Enable the New Administration’s Policy Priorities

Paul Hastings LLP on

Policy change in Washington since the change in administration has been swift, dramatic in many areas and executed with unprecedented pace. One area, however, has been relatively stable in the administration’s first two...more

Paul Hastings LLP

A Whirlwind of Change: The Delisting of Tornado Cash

Paul Hastings LLP on

Over the past several years, as U.S. regulators have grappled with the increasing use of cryptocurrency across a spectrum of legitimate and illegitimate commerce, the U.S. Department of Commerce’s Office of Foreign Assets...more

American Conference Institute (ACI)

Preparing for Latin American Sanctions

President Trump’s “America First Trade Policy” is creating new sanctions compliance risk for financial services institutions and companies in an area that historically has not received as much enforcement attention: drug...more

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more

The Volkov Law Group

Israeli Freight Forwarder Sentenced to Two Years in Prison for Violating U.S. Export Controls on Aircraft Components to Russia

The Volkov Law Group on

The recent sentencing of Israeli freight forwarder Gal Haimovich to two years in federal prison for violations of U.S. export controls serves as a striking example of the aggressive enforcement posture adopted by U.S....more

BakerHostetler

Weekly Blockchain Blog - March 2025 #2

BakerHostetler on

Executive Order Establishes Strategic Bitcoin Reserve, Digital Asset Stockpile - On March 6, President Trump issued an executive order (EO), Establishment of the Strategic Bitcoin Reserve and United States Digital Asset...more

Foley & Lardner LLP

What Every Multinational Company (Doing Business in Mexico) Should Know About … Mitigating Risks From ATA Scrutiny in a New...

Foley & Lardner LLP on

Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more

Jones Day

Mitigating Risk From the Designation of Cartels as FTOs and SDGTs

Jones Day on

The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more

Baker Botts L.L.P.

U.S. Intensifies Its Drive to Penalize Traders and Shippers of Sanctioned Country Oil

Baker Botts L.L.P. on

In another step to deprive a sanctioned country of revenues from petroleum sales, the U.S. government recently sanctioned more than 30 entities and vessels located around the world for their role in brokering the sale and...more

Bass, Berry & Sims PLC

Haas Automation Agrees to Pay More Than $2.5 Million to Settle Sanctions and EAR Violations

Bass, Berry & Sims PLC on

On January 17, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) announced that Haas Automation Inc. (Haas) agreed to settle potential civil...more

Cooley LLP

OFSI Steps Up: The Future of UK Sanctions Enforcement

Cooley LLP on

In the past year, the UK Office of Financial Sanctions Implementation (OFSI) actively has focused on sanctions enforcement efforts, particularly with respect to Russia-related measures (Russia sanctions), including by...more

BakerHostetler

White House Increases Scrutiny on Foreign Investors: Why FOCI Is a Concern for International Businesses

BakerHostetler on

Foreign Ownership, Control, or Influence (FOCI) refers to a situation where a foreign entity has the power to directly or indirectly influence the management or operations of a company. FOCI can result from legal means like...more

Troutman Pepper Locke

US Declares War on Cartels: Historic Terrorist Designations Reshape Sanctions Compliance Risks

Troutman Pepper Locke on

On February 20, 2025, the U.S. Departments of State and the Treasury designated eight Latin American drug trafficking cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), in...more

K2 Integrity

2024 in Review: A Year of Expanded Sanctions and Trade Controls and Increased Enforcement Actions

K2 Integrity on

In 2024, global sanctions and trade controls continued to expand, with the United States (U.S.), European Union (EU), and United Kingdom (UK) leading the charge against actors threatening international security and financial...more

Wiley Rein LLP

[Podcast] The Iron Fist of General Sani Abacha, Nigeria's Ruthless Dictator

Wiley Rein LLP on

Join hosts Tatiana Sainati and Diana Shaw as they delve into the gripping story of General Sani Abacha, the Nigerian dictator who embezzled billions of dollars and ruled with an iron fist from 1993 to 1998. Known for his...more

Bracewell LLP

Guiding Your Company Through Trump’s New Latin America Enforcement Policy

Bracewell LLP on

Shortly after President Trump’s second inauguration, his executive branch took steps to further one of his signature promises: securing the southern border. While these actions primarily impact immigration laws, several...more

BakerHostetler

Requiem for Task Force KleptoCapture: The Future of Russia Sanctions Enforcement

BakerHostetler on

On February 5, 2025, the new Attorney General announced the disbanding of Task Force KleptoCapture, which was launched in March 2022 to enforce the sweeping portfolio of sanctions against Russia. KleptoCapture was part of an...more

DLA Piper

AG Bondi Releases Memos on Cartels and Joint Task Force October 7: Implications for Industry

DLA Piper on

The US Department of Justice (DOJ)’s Attorney General, Pam Bondi, recently released over a dozen memoranda on a variety of policies – ranging from plea agreements and sentencing criteria, to the DOJ’s amplified focus on...more

Baker Botts L.L.P.

Compliance and Enforcement Takeaways from the Attorney General’s February 5, 2025 Memos

Baker Botts L.L.P. on

On February 5, 2025, the newly sworn-in United States Attorney General, Pamela Bondi, issued 14 memos to DOJ employees. The memos make clear that, under AG Bondi, DOJ’s enforcement efforts will focus on (i) immigration...more

Guidepost Solutions LLC

Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more

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