News & Analysis as of

Sanction Violations FinCEN

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

The Volkov Law Group

DOJ and OFAC Sanctions and Export Control Detection Strategies

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In this new aggressive era of sanctions and export controls enforcement, companies need to understand the potential risks that DOJ and/or OFAC may identify a company for sanctions investigation....more

Kohn, Kohn & Colapinto LLP

FinCEN Head Praises New AML Whistleblower Program

The passage of the Anti-Money Laundering (AML) Whistleblower Improvement Act in December 2022 was heralded by whistleblower advocates as a major development which would transform the ability of the U.S. to crack-down on money...more

Orrick, Herrington & Sutcliffe LLP

OFAC Signals Willingness to Use FinCEN Whistleblower Incentive Program for Sanctions Violations

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced two enforcement actions this year. Both reference the Financial Crimes Enforcement Network's (FinCEN) whistleblower program,...more

K2 Integrity

FINCast Ep. 39 – State of Russia Sanctions Two Years After the Invasion

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On FINCast Episode 39, Juan Zarate sits down with K2 Integrity’s Katya Hazard and Amir Fadavi to discuss the state of Russia-related sanctions and to explore what has worked and what may require further coordinated efforts to...more

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2023 Trends and Lessons Learned

Today’s alert—the second in our Sanctions 2023 Year in Review Series—provides an overview of U.S. sanctions enforcement in 2023, including the key lessons learned from the public enforcement actions issued by the U.S....more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

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The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

Proskauer - Blockchain and the Law

Don’t Get Caught Up in the Mix: OFAC Sanctions Another Crypto Mixer for Potential Violations of Sanctions Regulations and FinCEN...

U.S. government agencies continue to take action against cryptocurrency mixing services that enable cybercriminals to obfuscate the trail of stolen proceeds on public blockchains stemming from illicit cyber activity. On...more

Akin Gump Strauss Hauer & Feld LLP

7 Enforcement Predictions For US Export Controls, Sanctions

Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – November 2023 Update

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You are reading the November 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. ...more

Sheppard Mullin Richter & Hampton LLP

OFAC Sanctions Crypto Mixer Following Allegations of Laundering Funds to North Korea

The U.S. authorities are increasingly taking actions against big-name crypto mixers for potential violations of sanctions regulations. On November 29, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control...more

Sheppard Mullin Richter & Hampton LLP

Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History

On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more

Hogan Lovells

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

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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

American Conference Institute (ACI)

Navigating U.S. Sanctions and Export Control Restrictions

Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2022 Trends and Lessons Learned

Today’s alert—the third and final installment in our Sanctions 2022 Year in Review series—provides an overview of U.S. sanctions enforcement in 2022, including the key lessons learned from the enforcement actions issued by...more

The Volkov Law Group

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

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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

The Volkov Law Group

OFAC and FinCEN Reach Settlement Agreement with Virtual Currency Exchange Bittrex (Part I of II)

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On October 11, 2022, the Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced settlement agreements with Bittrex, Inc. (“Bittrex”), a cryptocurrency exchange based in...more

K2 Integrity

Opportunities, Risks, and Compliance in the Digital Assets Space

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On 14 September 2022, K2 Integrity hosted a webinar on considerations in the digital assets space. K2 Integrity Board Member Christopher Brummer and AML/CFT experts Mariano Federici and Alex Levitov discussed the current...more

American Conference Institute (ACI)

Compliance measures to address sanctions enforcement: ‘the new FCPA’

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

Buchalter

Congress Makes Sweeping Changes to Money Laundering Enforcement

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On New Year’s Day 2021, Congress passed—over President Trump’s veto—a defense appropriations law containing the Anti-Money Laundering Act of 2020 (“AML Act”) and the Corporate Transparency Act, as part of a sweeping new set...more

Skadden, Arps, Slate, Meagher & Flom LLP

Compliance in a Time of Crisis

Addressing the Evolving Risks - Warren Buffett said that “only when the tide goes out do you discover who’s been swimming naked.” Buffett was not talking about compliance programs in a time of crisis, but his wisdom applies...more

Orrick - On the Chain

Cryptocurrency and OFAC: Beware of the Sanctions Risks

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A recent federal criminal action shows the depth of the U.S. government’s concern about the use of cryptocurrency (or virtual currency) to violate economic sanctions laws and the lengths to which it will go to charge such...more

Dechert LLP

US Blockchain Enforcement and Litigation Update

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Over the past two years, prices for cryptocurrencies and other digital assets have experienced extreme gains and declines, while billions of dollars have been raised through Initial Coin Offerings (“ICOs”). In this dynamic...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

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TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - November 2017

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including new U.K. reporting obligations for sanctions violations,...more

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