The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
Understanding the Additional Risks When Making a Ransomware Payment
WorldSmart: The Extraordinary Sanctions Against Russia - What Happens Next?
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
Compliance Perspectives: Sanctions, Data and Vetting Third Parties
FINCast Ep. 19 - The DPRK Sanctions Program
Episode 118 -- Update on OFAC Enforcement and Lessons Learned
On January 10, 2025, the US government issued the latest round of sanctions targeting Russia’s revenue sources used to fund its war in Ukraine....more
In an effort to reduce Russian energy revenues being used to fund the war against Ukraine, on January 10, 2025, the United States Department of the Treasury's Office of Foreign Assets Control (OFAC), issued a “determination”...more
Days before President Biden leaves the White House, the U.S. government has delivered a major blow against Russia. On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced...more
On January 10, 2025, in a final action to, among other things, deter Russian aggression on the international stage, the US Department of the Treasury enacted sweeping new sanctions on the Russian energy sector. Specifically,...more
Throughout 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control ("OFAC") published 12 enforcement actions regarding alleged sanctions violations by foreign and domestic persons and entities....more
U.S. investors interested in investing in advanced Chinese technology companies may now be constrained by the U.S. Government’s first-ever outbound investment rule (Final Rule) which took effect on Jan. 2, 2025. The Final...more
The US government signals careful optimism with a new general license authorizing some previously prohibited transactions, including many (but not all) transactions with Syrian governing institutions, for the next six months....more
On December 18, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 1B (Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue...more
In a significant development underscoring the U.S. government’s continued efforts to counter Russia’s destabilizing activities, the U.S. Department of the Treasury recently announced the designation of Gazprombank as a...more
Digital Asset Companies Achieve Licenses, Launch Stablecoin Products - According to a recent press release, Anchorage Digital, a digital asset platform and infrastructure provider, announced that the New York State...more
California Doctor to Pay $3 Million for Insider Trading - On December 18, a California oncologist agreed to pay the US Securities and Exchange Commission (SEC) $3 million to resolve allegations of insider trading. The SEC...more
Shortly before Thanksgiving, a panel of the United States Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) did not have the authority to sanction Tornado Cash, which offers a...more
Few areas will be as impacted by the incoming second Trump administration as international trade policy. Check out our team’s assessment of what the coming year may bring for trade regulation and enforcement. Husch...more
On November 26, 2024, the US Court of Appeals for the Fifth Circuit ruled that “immutable” smart contracts are not “property” for purposes of regulation by the US Department of the Treasury’s Office of Foreign Assets Control...more
On 10/9/24, the Bureau of Industry and Security (BIS) within the Department of Commerce has issued guidance aimed at financial institutions (FIs), outlining best practices for adherence to the Export Administration...more
U.S. sanctions laws present complex conflicts with state insurance laws. While state laws govern the timely payment of claims and other insurance practices, U.S. sanctions administered by the U.S. Department of the Treasury’s...more
The Fifth Circuit held that Tornado Cash, open-source computer code known as an immutable “smart contract”, is not “property” and thus cannot be subject to blocking sanctions pursuant to IEEPA and EO 13694....more
The court ruled OFAC overstepped its authority in sanctioning Tornado Cash, holding that its smart contracts are not “property” under the governing statutes....more
On November 26, 2024, the Fifth Circuit Court of Appeals held that the United States Office of Foreign Assets Control (“OFAC”) exceeded its authority by adding an entity that pools and anonymizes crypto transactions to OFAC’s...more
On November 26, the U.S. Court of Appeals for the Fifth Circuit reversed and remanded a decision by the district court regarding the Office of Foreign Assets Control’s (OFAC) designation of a virtual currency mixer software...more
Marking what appears to be a reversal of previous policy, the Office of Foreign Assets Control (OFAC) determined that US persons can, subject to certain limitations, include sanctioned persons as speakers at overseas...more
You've been hit by a ransomware attack, and a cybercriminal group is demanding a cryptocurrency payment in exchange for your data's safe return. Should you pay? Deciding whether to pay a ransom is an internal business...more
On November 26, the U.S. Fifth Circuit Court of Appeals overturned sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) against a decentralized cryptocurrency mixing service (a...more
New Crypto Products Announced by Financial Services Firms, Exchanges, DEXs - A major U.S. cryptocurrency exchange recently announced that it has integrated a major mobile payments application into its Onramp tool to enable...more
In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado...more