The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Aug. 28, 2024, issued a final rule to help safeguard the investment adviser sector from illicit finance activity (Final Rule). The Final...more
9/6/2024
/ AML/CFT ,
Bank Secrecy Act ,
Biden Administration ,
Compliance ,
Customer Due Diligence (CDD) ,
Final Rules ,
Financial Institutions ,
FinCEN ,
NPRM ,
Popular ,
Registered Investment Advisors ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 26, 2024, issued a notice containing a reference guide for customers of financial institutions (the Reference Guide). The Reference...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on June 28, 2024, announced a proposed rule to "strengthen and modernize financial institutions' anti-money laundering and countering the...more
7/15/2024
/ AML/CFT ,
Anti-Money Laundering ,
Board of Directors ,
Compliance ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Oversight Committee ,
Proposed Rules ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding
Nearly six months after President Joe Biden signed an executive order (EO) authorizing secondary sanctions against Foreign Financial Institutions (FFIs) conducting or facilitating significant transactions with certain...more
6/25/2024
/ Biden Administration ,
Compliance ,
Economic Sanctions ,
Evasion ,
Executive Orders ,
Financial Transactions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
U.S. Treasury
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR), 31 CFR Part 515, to promote internet freedom in Cuba, support independent Cuban private-sector...more
5/30/2024
/ Amended Regulation ,
Bank Accounts ,
Banking Sector ,
Biden Administration ,
Blocked Person ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Development ,
Entrepreneurs ,
Financial Services Industry ,
Foreign Nationals ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Private Sector ,
SDN List
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License 44A (GL 44A) on April 17, 2024, replacing and superseding General License 44 (GL 44). On Oct. 18, 2023, OFAC suspended...more
Please join Holland & Knight's Financial Services Regulatory Team for a roundtable discussion on what to expect on the financial services landscape in 2024. Our attorneys will present on a wide range of topics in a "3-Minute...more
1/3/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Continuing Legal Education ,
Federal Trade Commission (FTC) ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Regulatory Agencies ,
Financial Services Industry ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Securities and Exchange Commission (SEC) ,
Webinars
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 18, 2023, suspended certain U.S. sanctions under the Venezuela Sanctions Regulations (VSR), including measures on Venezuela's oil and gas...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) released proposed regulations on Jan. 24, 2022, for implementing a pilot program allowing financial institutions to share suspicious activity...more
1/28/2022
/ Anti-Money Laundering ,
Comment Period ,
Financial Institutions ,
FinCEN ,
Foreign Jurisdictions ,
Foreign Subsidiaries ,
Internal Controls ,
Proposed Regulation ,
Reporting Requirements ,
Subsidiaries ,
Suspicious Activity Reports (SARs)
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) released proposed regulations on Dec. 7, 2021, seeking to implement the "beneficial ownership information" (BOI) requirement of the Corporate...more
12/15/2021
/ AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
Commodity Exchange Act (CEA) ,
Corporate Transparency Act ,
Disclosure Requirements ,
FinCEN ,
NPRM ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more
7/7/2021
/ AML/CFT ,
Anti-Corruption ,
Anti-Money Laundering ,
Banking Sector ,
Biden Administration ,
Cyber Crimes ,
Drug Trafficking ,
Enforcement Priorities ,
Financial Institutions ,
FinCEN ,
Fraud ,
Human Trafficking ,
Mexico ,
Money Laundering ,
New Guidance ,
Nonbank Firms ,
Office of Foreign Assets Control (OFAC) ,
Policy Statement ,
Popular ,
Russia ,
Significant Transnational Criminal Organization ,
Smuggling ,
State Sponsors of Terrorism ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing Regulations ,
U.S. Treasury ,
Virtual Currency
The Anti-Money Laundering Act of 2020 (AMLA 2020) became law on Jan. 2, 2020, when Congress overrode President Donald Trump's veto of the National Defense Authorization Act. AMLA 2020 is the most consequential anti-money...more
1/14/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Congressional Override ,
Criminal Penalties ,
Customer Due Diligence (CDD) ,
Financial Institutions ,
FinCEN ,
Foreign Banks ,
Mutual Legal Assistance Treaties (MLAT) ,
NDAA ,
Presidential Veto ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers
In an effort to curb the Cuban regime from "redirecting revenue from authorized U.S. travel for its own benefit," as stated by U.S. Department of the Treasury Secretary Steven T. Mnuchin, the Office of Foreign Assets Control...more
• President Donald Trump has issued an Executive Order expanding the current sanctions relating to Venezuela by blocking all property and interests in property of the government of Venezuela and the Nicolás Maduro...more
8/8/2019
/ Banking Sector ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
General Licenses ,
Human Rights ,
Humanitarian Assistance ,
Office of Foreign Assets Control (OFAC) ,
Politically Exposed Person (PEPs) ,
SDN List ,
Secretary of the Treasury ,
Trump Administration ,
Venezuela
• The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce's Bureau of Industry and Securities (BIS) announced changes to the Cuban Assets Control Regulations (CACR)...more
6/6/2019
/ Aircraft ,
Airline Passengers ,
Bureau of Industry and Security (BIS) ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Export Administration Regulations (EAR) ,
Federal Aviation Administration (FAA) ,
Foreign Relations ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
p2p ,
Sanctions ,
Trump Administration ,
Vessels
• Effective May 2, 2019, the Trump Administration will not continue the waiver against lawsuits under Title III of the Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996, also known as the Helms-Burton Act.
•...more
4/26/2019
/ Civil Liability ,
Cuba ,
Extraterritoriality Rules ,
Foreign Nationals ,
International Travel ,
Office of Foreign Assets Control (OFAC) ,
Personal Jurisdiction ,
Trafficking ,
Trump Administration ,
US State Departments ,
WTO
• National Security Advisor Ambassador John Bolton issued a statement threatening sanctions against non-U.S. banks for facilitating illegitimate transactions with certain Venezuelan individuals and entities.
• This...more
3/14/2019
/ Banking Sector ,
Blocked Entities ,
Cross-Border Transactions ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Venezuela
• The Trump Administration is allowing U.S. nationals to pursue civil actions against certain Cuban entities under Title III of the Helms-Burton Act (Libertad Act) for trafficking in property confiscated by the Cuban...more
• The U.S. Department of the Treasury's (Treasury) Office of Foreign Assets Control (OFAC) has designated five officials affiliated with the regime of Nicolas Maduro pursuant to Executive Order 13850 (E.O. 13850), including...more
• Pursuant to Executive Order 13850 (E.O. 13850), the U.S. Department of the Treasury's (Treasury) Office of Foreign Assets Control (OFAC) designated Petroleos de Venezuela, S.A. (PdVSA), effectively blocking PdVSA's property...more
1/31/2019
/ Banking Sector ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Petroleum ,
SDN List ,
Trump Administration ,
Venezuela
• President Donald Trump has issued an Executive Order (the E.O.) imposing additional sanctions with respect to the situation in Venezuela, and the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has...more
8/29/2017
/ Blocked Person ,
Citgo ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
SDN List ,
Trump Administration ,
Venezuela
• The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) continues to expand its Geographic Targeting Orders (GTOs) with respect to beneficial ownership transparency in real estate...more
On July 25, 2017, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a revised set of frequently asked questions (FAQs) further clarifying the scope and implementation process for the...more
7/31/2017
/ Amended Regulation ,
Contract Terms ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Grandfathered Status ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Travel Restrictions ,
Trump Administration ,
U.S. Treasury
On the afternoon of June 16, 2017, shortly before President Donald Trump announced new changes to the U.S.-Cuba policy, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued 12 frequently asked...more
6/19/2017
/ Cross-Border Transactions ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Exports ,
Imports ,
International Remittance Transfers ,
Military Contracts ,
Travel Restrictions ,
Trump Administration
The Financial Crimes Enforcement Network (FinCEN) on Aug. 25, 2016, issued a notice of proposed rulemaking (Proposed Rule) to implement Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools...more
8/29/2016
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Financial Institutions ,
FinCEN ,
Non-Resident Aliens ,
Puerto Rico ,
Regulatory Standards ,
Virgin Islands