News & Analysis as of

Suspicious Activity Reports (SARs) Economic Sanctions

K&L Gates LLP

The Latest OFSI Property and Related Services Threat Assessment

K&L Gates LLP on

The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) has published a report detailing suspected breaches of UK financial sanctions involving UK property and related services firms since February 2022 and...more

The Volkov Law Group

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

The Volkov Law Group on

On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls...more

Bracewell LLP

“Export Controls Are the New Sanctions” and Other Enforcement Trends for 2024

Bracewell LLP on

2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more

Foodman CPAs & Advisors

Financiamiento Del Terrorismo: Señales De Alerta De FinCEN

Foodman CPAs & Advisors on

El 20/10/23, FinCEN emitió Señales de Alerta (“Red Flags”) sobre el Financiamiento del Terrorismo para ayudar a las instituciones financieras a identificar flujos de financiamiento para la organización terrorista Hamás en...more

Hogan Lovells

U.S. regulators issue joint notice concerning SAR key term and global evasion of trade controls

Hogan Lovells on

On 6 November 2023, the Department of the Treasury’s Financial Crimes Enforcement Network and the Department of Commerce’s Bureau of Industry and Security issued a joint notice concerning a new Suspicious Activity Report key...more

The Volkov Law Group

BIS and FinCEN Release Joint Notice Concerning Global Export Control Evasion

The Volkov Law Group on

On November 6, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released a new joint notice concerning...more

Fenwick & West LLP

U.S. Government Intensifies Focus on Russian Sanctions Evasion

Fenwick & West LLP on

The U.S. government is turning up the dial on its efforts to combat evasion of export controls and sanctions against Russia. The severe trade restrictions against Russia (and Belarus) have seen continuous escalation since...more

Ballard Spahr LLP

FinCEN Analysis Reveals Patterns and Trends in Suspected Evasion of Russia-Related Export Controls

Ballard Spahr LLP on

Following Russia’s invasion of Ukraine, the Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a joint alert and a supplemental alert (the...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Government Expands Enforcement Measures To Address Fraud and Money Laundering

On 22 September 2022, the U.K. government introduced the Economic Crime and Corporate Transparency Act 2022. The new bill is currently navigating its way through the U.K. Parliament and is likely to receive royal assent in...more

The Volkov Law Group

Bittrex’s Sanctions and AML Violations: The Importance of Compliance Controls for the Cryptocurrency Industry (Part II of II)

The Volkov Law Group on

In parallel with the Office of Foreign Assets Control (“OFAC”), the Financial Crimes Enforcement Network (“FinCEN”) settled with Bittrex, Inc. (“Bittrex”), a cryptocurrency exchange that allows users to trader virtual assets,...more

Ballard Spahr LLP

OFAC and FinCEN Settle with Bittrex in Regulators’ First Parallel Virtual Currency Enforcement Actions

Ballard Spahr LLP on

The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...more

Venable LLP

Treasury Doubles Up Enforcement Efforts Against Noncompliant Crypto Platforms

Venable LLP on

​​​​​​​The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced yesterday that they had reached settlements for over $24 million and $29 million,...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK’s Red Alert on Financial Sanctions Evasion Signals Regulatory Alignment on Future Sanctions Enforcement

Amid the continued rollout of new sanctions measures in response to Russia’s invasion of Ukraine, the U.K. National Crime Agency (NCA) and HM Treasury’s Office of Financial Sanctions Implementation (OFSI) have jointly issued...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

Eversheds Sutherland (US) LLP

Financial Crime Horizon Scanner: 2022 - Q1 (US)

Our quarterly Financial Crime Horizon Scanner for the US summarizes key financial crime related legal and regulatory changes expected over the next 2 years and provides electronic links to key resources. We hope that you...more

Orrick - Finance 20/20

FinCEN Urges Financial Institutions to Focus on Detecting Proceeds of Foreign Public Corruption

Orrick - Finance 20/20 on

The Financial Crimes Enforcement Network (“FinCEN”) recently issued an advisory urging financial institutions (including certain cryptocurrency businesses) to implement controls to help detect proceeds of foreign public...more

White & Case LLP

US Regulators Seek to Prevent Use of Crypto to Circumvent Russia Sanctions

White & Case LLP on

Cryptocurrency's reputation for enabling transactions outside of the traditional financial ecosystem has prompted concerns that it may serve as a tool for Russian actors to evade recently promulgated sanctions against the...more

Troutman Pepper Locke

FinCEN Implores Vigilance From Financial Institutions in Anticipation of Attempted Russia Sanctions Evasion

Troutman Pepper Locke on

Following the significant sanctions and other restrictions imposed by the United States and its global allies resulting from the Russian Federation's invasion of Ukraine, the Financial Crimes Enforcement Network (FinCEN)...more

Harris Beach Murtha PLLC

Federal Financial Regulators Issue Warnings About Russian Sanction Evasion Attempts

With the imposition of sweeping new sanctions on Russia and Belarus following the invasion of Ukraine, federal financial regulators are issuing warnings about efforts to evade these actions. On Monday, March 7, 2022, the...more

Jones Day

FinCEN Warns Institutions of Sanctions Evasion Risks

Jones Day on

As the U.S. government's economic sanctions against Russia continue to grow, regulators are calling on financial institutions to help detect and prevent attempts to evade these measures through the use of convertible virtual...more

Ballard Spahr LLP

Russian Sanctions: FinCEN Provides Red Flags for Potential Evasion Attempts

Ballard Spahr LLP on

On March 7, the Financial Crimes Enforcement Network (“FinCEN”) issued an alert “advising all financial institutions to be vigilant against potential efforts to evade the expansive sanctions and other U.S.-imposed...more

Herbert Smith Freehills Kramer

FinCEN Warns of Russian Sanctions Evasion Attempts and Provides Guidance for Increased Vigilance

On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) of the Treasury Department published guidance on increased vigilance for potential Russian sanctions evasion attempts. The FinCEN Alert follows the...more

Dorsey & Whitney LLP

FinCEN Urges Financial Institutions to Guard Against Attempts to Evade Sanctions

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On March 7, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued an alert (the “FinCEN Alert”) urging financial institutions to proactively guard against possible attempts to evade recently implemented sanctions...more

Eversheds Sutherland (US) LLP

Sanctions 2.0: US Treasury Department announces results of sanctions policy review and OFAC releases compliance guidance for the...

The US Department of the Treasury (Treasury) has released the results of its review of economic and financial sanctions first announced in December 2020 by then President-elect Biden (Report). From that review, Treasury has...more

Hogan Lovells

Ransomware sanctions and the U.S. Government's latest strategy to address cyber threats

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The decision to pay millions to a cyber criminal has never been easy, but it is now even more complex. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory on September 21,...more

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