The US Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule on January 15 to implement changes to, and impose new licensing obligations under, the Export Administration Regulations...more
In the last two years, OFAC has brought four enforcement actions that focus on an organization’s “screening errors.” These include: American Express; (2) Cobham Metalics; (3) Apple; and (4) Amazon. In today’s posting, I will...more
On May 14, 2020, the U.S. Department of State, U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the U.S. Coast Guard jointly released a Sanctions Advisory for the Maritime Industry, Energy and...more
The United Nations and the United States Government have released significant reports that detail North Korea’s continued efforts to engage in wide-ranging sanctions evasion activity in support of its weapons of mass...more
On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more
On October 13, 2017, President Trump announced that he was “decertifying” Iran’s compliance with the Joint Comprehensive Plan of Action (“JCPOA”), the multi-nation agreement on Iran’s nuclear program that was implemented in...more
Although poor, out-of-touch Dr. Evil of the Austin Powers series had to resort to the threat of using a giant laser beam to decimate various cities to try to obtain his one million billion dollars in ransom, Kim Jong-un1...more
On May 25, the U.S. Treasury Department issued a finding designating North Korea as a jurisdiction of “primary money laundering concern.” On the same date, Treasury, through FinCEN, issued a notice of proposed rulemaking...more