U.S. Persons prohibited from transactions with anyone on the OFAC SDN List without a license, regardless of country. Includes entities owned in excess of 50-percent by one or more SDNs (33-percent for select Russian...more
8/14/2024
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
Financial Transactions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
Infrastructure ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List
This handy one-pager is designed to be used by our clients to provide a quick reference guide for the complex topics of trade sanctions and export control regulations. The goal is to briefly summarize key points for each...more
On April 22, 2024, the U.S. Department of Justice announced the indictment of 10 Venezuelan individuals for conspiring to violate the International Economic Emergency Powers Act (“IEEPA”). According to the DOJ, the...more
On April 17, 2024, OFAC formally rolled back the sanctions relief it previously provided to the Venezuelan oil and gas industry. While OFAC provided the initial relief believing that Venezuela would permit a fair and open...more
On March 26, 2024, the U.S. Department of Justice (“DOJ”) unsealed an indictment against prominent cryptocurrency exchange KuCoin and two of its founders, Chun Gan and Ke Tang. The DOJ charged the exchange and its founders...more
On March 5, 2024, the U.S. Securities and Exchange Commission (“SEC”) announced charges and a corresponding cease-and-desist order (the “Order”) with ShapeShift AG, a cryptocurrency exchange registered in Switzerland that...more
In Part I, we discussed the basics behind the UK Modern Slavery Act of 2015. To briefly reiterate, that Act requires any company doing business in the UK with an annual turnover of £36 million or more to publicize their...more
3/12/2024
/ Compliance ,
Corporate Governance ,
Corporate Social Responsibility ,
Corruption ,
Forced Labor ,
Human Rights ,
Human Trafficking ,
Modern Slavery Act ,
Risk Management ,
Supply Chain ,
UK
If you follow our blog, you’ll notice lately we’ve been writing frequently on topics related to human trafficking and modern slavery. This is no accident, as new laws and regulations related to this growing area of...more
On February 28, 2024, President Biden issued a new Executive Order in order to better secure the private data of U.S. citizens from being exploited by foreign adversaries of the United States. By issuing his Executive Order...more
3/7/2024
/ Biden Administration ,
Data Brokers ,
Data Protection ,
Data Security ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Due Diligence ,
Economic Sanctions ,
Executive Orders ,
Foreign Adversaries ,
International Emergency Economic Powers Act (IEEPA) ,
Personal Data ,
Risk Management
On February 7, 2024, the U.S. Securities and Exchange Commission (“SEC”) announced charges and a related cease-and-desist order (the “Order”) against TradeStation Crypto, Inc. (“TradeStation”) for failing to register the...more
2/28/2024
/ Crypto Exchanges ,
Cryptocurrency ,
Digital Platforms ,
Digital Wallets ,
Enforcement Actions ,
Failure to Comply ,
Fines ,
Investment Contract ,
Investment Platforms ,
NASAA ,
Offerings ,
Penalties ,
Securities Regulation ,
Securities Violations ,
Unregistered Securities
Following the death of opposition politician Alexey Navalny, the Biden Administration announced a large swath of new and additional sanctions on the Russian Federation. The U.S. Department of Treasury’s Office of Foreign...more
2/27/2024
/ Biden Administration ,
Critical Infrastructure Sectors ,
Economic Sanctions ,
Enforcement Priorities ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Vladimir Putin
Easy come, easy go. On January 29, 2024, OFAC published General License 43A under the Venezuela Sanctions Regulations, which partially rolled back a piece of the sanctions relief it provided to the country only a few months...more
El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados Unidos tomó varias medidas para proporcionarle a Venezuela un alivio limitado a las sanciones...more
Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs....more
On December 23, 2023, BarnBridge DAO (“BarnBridge”) and its founders, Tayler Ward and Troy Murray, agreed to settle charges with the U.S. Securities and Exchange Commission (“SEC”). BarnBridge violated Sections5(a) and 5(c)...more
2/1/2024
/ Blockchain ,
Cryptoassets ,
Cryptocurrency ,
Decentralized Autonomous Organization (DAO) ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Enforcement Actions ,
Investment Products ,
Popular ,
Securities Act ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations ,
Structured Financial Products
On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more
12/19/2023
/ Compliance ,
Corruption ,
Crimea ,
Crypto Exchanges ,
Cryptocurrency ,
Economic Sanctions ,
Enforcement Actions ,
Initial Coin Offering (ICOs) ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanction Violations ,
Ukraine ,
White Collar Crimes
Binance’s $4.3 billion fine is one of the largest penalties the DOJ has ever obtained from a corporate defendant. Furthermore, its founder and CEO Changpeng Zhao (“CZ”) was also personally subject to a fine, amounting to...more
12/14/2023
/ BSA/AML ,
Criminal Prosecution ,
Crypto Exchanges ,
Cryptoassets ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Services Industry ,
Financial Transactions ,
FinCEN ,
FinTech ,
Money Transmitter ,
Settlement ,
Statutory Violations
Binance’s settlement with the DOJ represents one of the largest criminal corporate enforcement actions ever. A review of the facts reveals that the penalty is likely warranted, as the misconduct was driven from the very...more
12/13/2023
/ BSA/AML ,
Criminal Prosecution ,
Crypto Exchanges ,
Cryptoassets ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Services Industry ,
Financial Transactions ,
FinTech ,
Know Your Customers ,
Money Transmitter ,
Settlement ,
Statutory Violations
On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as...more
12/12/2023
/ BSA/AML ,
CFTC ,
Criminal Prosecution ,
Crypto Exchanges ,
Cryptoassets ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Services Industry ,
Financial Transactions ,
FinCEN ,
FinTech ,
Guilty Pleas ,
International Emergency Economic Powers Act (IEEPA) ,
Money Transmitter ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Settlement ,
Statutory Violations
On November 1, 2023, the U.S. Department of Justice (“DOJ”) and U.S. Securities and Exchange Commission (“SEC”) brought charges against cryptocurrency project SafeMoon LLC and its U.S. subsidiary SafeMoon US LLC, along with...more
11/17/2023
/ Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Financial Fraud ,
Financial Services Industry ,
Popular ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations ,
Unregistered Securities
Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de EE.UU. promulgó una serie de licencias generales al gobierno de Venezuela para brindarle un alivio al país de las sanciones económicas. La OFAC promulgó...more
11/8/2023
/ Compliance ,
Corruption ,
Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Relief Measures ,
Venezuela ,
White Collar Crimes
As we discussed previously, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently provided Venezuela with much needed sanctions relief. Specifically, OFAC issued General License 44 (among...more
11/7/2023
/ Compliance ,
Corruption ,
Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Relief Measures ,
Venezuela ,
White Collar Crimes
Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs.
About the document: ...more
11/1/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Embargo ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List
El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados Unidos tomó varias medidas para proporcionar un alivio (limitado) de sus sanciones económicas en...more
On October 18, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) took several steps to provide Venezuela with some limited relief from its sanctions. The relief includes General Licenses...more
10/23/2023
/ Compliance ,
Corruption ,
Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Relief Measures ,
Venezuela ,
White Collar Crimes