News & Analysis as of

Office of Foreign Assets Control (OFAC) Financial Institutions Banks

Ballard Spahr LLP

Bank’s Digital Assets Business Strategy Draws Federal Reserve Scrutiny

Ballard Spahr LLP on

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

Williams Mullen

New Russia Sanctions Target Foreign Financial Institutions, Expand Import Bans

Williams Mullen on

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

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

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

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

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

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

Ballard Spahr LLP on

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

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

Skadden, Arps, Slate, Meagher & Flom LLP

New US Restrictions Impact Russia-Related Imports and Exports, US Dollar-Denominated Banknotes

On March 11, 2022, President Joe Biden signed Executive Order 14068 (E.O. 14068) imposing new restrictions on imports and exports with respect to Russia as well as on the supply of U.S. dollar-denominated banknotes to the...more

Faegre Drinker Biddle & Reath LLP

Russian Financial Sector Sanctions: A Summary

The international sanctions targeting the Russian Federation include significant financial sanctions against Russian banks. We’re monitoring these actions and have created a summary of financial sanctions against Russian...more

NAVEX

Staying Ahead of Sanctions – What You Need to Know to Maintain Compliance

NAVEX on

The threats posed by Russia to the Ukraine, and the worldwide implications, are deeply concerning and we denounce the invasion of the Ukraine by Russia and hope that this crisis can be resolved quickly through diplomacy. ...more

Bass, Berry & Sims PLC

Russia, Ukraine: Update as of the Evening of February 28

This UPDATED post summarizes the situation as of late evening on Monday, February 28, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our post of late evening on...more

Moore & Van Allen PLLC

United States Imposes Sanctions Related to Russia’s Invasion of Ukraine

In February 2014, the Revolution of Dignity or Maidan revolution in Ukraine resulted in the ousting of Ukrainian President Viktor Yanukovych. In the months that followed, Russia annexed the Crimea region of Ukraine and...more

Sheppard Mullin Richter & Hampton LLP

A Ruble Without a Cause: What Economic Sanctions on Russia May Mean for Your Business and Global Finance

With Russian forces massing at the Ukrainian border, the U.S. and EU have been warning of severe economic sanctions. While we wait and watch this brinksmanship play out, it is worth considering how businesses, and...more

A&O Shearman

Sanctions Roundup: Third Quarter 2021

A&O Shearman on

The Biden Administration this quarter announced fewer targeted sanctions, but issued several “whole of government” advisories regarding sanctions risks associated with China-related business dealings, as well as virtual...more

American Conference Institute (ACI)

[Event] 15th Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance - December 7th - 8th, Washington, DC

LIVE and IN-PERSON ACI’s Flagship Conference in December! ACI’s 15th Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance is North America’s largest and most comprehensive conference on economic...more

McGlinchey Stafford

BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]

McGlinchey Stafford on

The Bank Secrecy Act (BSA) and parts of the U.S. Patriot Act’s Office of Foreign Asset Control (OFAC) requirements have seemingly similar goals: to prevent money laundering and the funding of terrorist activities. Yet a...more

The Volkov Law Group

OFAC Settles with Bank of China for $2.3 Million for Violation of Now-Repealed Sudan Sanctions Program (Part II of IV)

The Volkov Law Group on

The UK-based Bank of China agreed to pay $2.3 million to settle violations of OFAC’s Sudan Sanctions Program.  OFAC repealed the Sudan sanctions in October 2017 but is continuing to investigate violations of the Sudan...more

American Conference Institute (ACI)

[Virtual Conference] Navigating Russia Sanctions Complexities - September 27th, 10:00 am - 5:00 pm EDT

Unravel the multiple layers of primary and secondary Russia Sanctions and strengthen your analytical decision-making process. The Russia sanctions landscape continues to evolve in many significant ways. ACI’s 4th...more

Sheppard Mullin Richter & Hampton LLP

The EU – U.S. Sanctions Dilemma: The Advocate General of the European Court of Justice Weighs in

In May 2018 the United States announced the reinstitution of sanctions against Iran that had previously been lifted pursuant to the Joint Comprehensive Plan Action (“JCPOA”). The U.S. sanctions on Iran that were revived...more

American Conference Institute (ACI)

[Virtual Event] Asia Pacific Conference on Economic Sanctions Compliance and Enforcement - May 27th - 28th, 9:00 am - 1:15 pm SGT

ACI’s Asia-Pacific Advanced Conference on Economic Sanctions Compliance and Enforcement is the largest sanctions gathering in Asia for financial institutions and global exporters. This unique conference features senior...more

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