FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more
3/15/2024
/ AML/CFT ,
Anti-Corruption ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
CDD ,
CFIUS ,
China ,
Customer Identification Program (CIP) ,
Due Diligence ,
Exempt Reporting Advisers (ERAs) ,
Financial Institutions ,
FinCEN ,
Infrastructure ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investors ,
No-Action Letters ,
Popular ,
Private Funds ,
Proposed Rules ,
Risk Assessment ,
Russia ,
Securities and Exchange Commission (SEC) ,
SIFMA ,
Suspicious Activity Reports (SARs) ,
Technology Sector
This post marks the third entry in our Year-in-Review series. For prior posts, click here. Many of the first measures that the United States, European Union and United Kingdom collectively took against Russia in 2022 related...more
This post marks the second entry in our Year-in-Review series. For prior posts, click here. Few sectors have been more affected by the sanctions on Russia than the energy industry....more
On February 24, 2022, the United States (U.S.), European Union (EU), United Kingdom (UK), and other countries issued a barrage of sanctions against the Russian financial sector, cutting off many major banks from the global...more
On December 5, 2022, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $60 per barrel price cap on maritime transfers of Russian-origin crude oil. The final cap level is being implemented...more
Various reports indicate that the Group of Seven nations (G7) will announce its initial capped price for Russian-origin crude oil transported by maritime means (“seaborne”) this week. The cap will come into effect on December...more
In the final few days of September, the U.S. and global allies issued a number of sanctions and export controls against actors who have supported Russia’s referendums in Ukraine and related attempts to annex four Ukrainian...more
Russian government approval is now required for Western companies to exit LLCs, which complicates and will likely delay exit strategies.
High-profile projects and industries, such as Sakhalin-2, continue to be targeted by...more
Takeaways - The G7 has announced consensus on a price cap for Russian origin oil and petroleum products to be implemented across a wide coalition of countries....more
The Russian government’s response to the introduction of Western sanctions has primarily focused on efforts to support and stabilize the Russian currency and economy.
In certain instances, the Russian government has...more
Russia has recently taken measures to allow its companies to continue the use of foreign intellectual property rights without consent from the rightsholder.
Payments for this use will now be made to a special “O” account...more
On May 8, 2022, the White House announced a number of new measures in response to Russia’s ongoing war in Ukraine. The new measures include prohibitions on new categories of services to Russia by U.S. persons; export controls...more
In the last month, the United States and global allies have issued unprecedented sanctions against Russia in response to the war in Ukraine. These sanctions apply ever-expanding pressure on the Russian economy and touch...more
On February 27, 2022, the U.S., UK, and EU announced their agreement that certain Russian banks would be delisted from the Belgian-based Society for Worldwide Interbank Financial Telecommunication (SWIFT). ...more
3/8/2022
/ Delisting ,
Economic Sanctions ,
EU ,
Financial Institutions ,
Financial Transactions ,
Foreign Relations ,
General Licenses ,
Military Conflict ,
Russia ,
SWIFT ,
UK ,
Ukraine
On February 24, 2022, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued a final rule effective immediately imposing sweeping export control restrictions against Russia in response to Russia’s...more
3/3/2022
/ Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Licensing Rules ,
Military End Use ,
Russia ,
U.S. Commerce Department ,
Ukraine
The EU and UK have imposed further sanctions in response to the invasion of Ukraine and the recognition by Russia of the Donetsk and Luhansk People’s Republics (“DNR” and “LNR”) of Ukraine as independent territories....more
Despite months of posturing and growing geopolitical tensions, Russia’s full-scale invasion of Ukraine this week was a shock to the global community. Western leaders have been swift and unanimous in their response, condemning...more
2/28/2022
/ Anti-Money Laundering ,
Asset Freeze ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
ECCNs ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
On February 24, 2022, in response to Russia’s attack on Ukraine, President Biden announced further sanctions on Russian individuals and entities. These measures are in addition to those already announced on February 22 and 23...more
On February 24, 2022, the U.S. Government issued a number of sanctions measures in response to Russia’s attack on Ukraine. These measures include sweeping financial sanctions and stringent export controls, which will have...more
2/25/2022
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Embargo ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
U.S. Treasury ,
Ukraine
On February 22 and 23, 2022, President Biden announced further sanctions in response to Russia’s invasion of Ukraine. These sanctions build upon the U.S. sanctions issued on February 21, 2022. Specifically, the additional...more
Initial Global Sanctions on Russia in Response to Events in Eastern Ukraine - In response to President Putin’s televised recognition of Donetsk and Luhansk People’s Republics (“DNR” and “LNR”) of Ukraine as “independent”...more
On April 15, 2021, the U.S. Government announced broad new sanctions authorities that can be used to target Russia and implemented limitations on dealings in Russian sovereign debt. These measures were imposed pursuant to a...more
On December 14, 2020, the U.S. Department of State initiated a series of sanctions pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) that target the Turkish Presidency of Defense...more
On December 31, 2019, the U.S. District Court for the Northern District of Texas overturned a $2 million fine imposed by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) against ExxonMobil Corp., and...more
On August 8, 2018, the State Department announced that it had concluded that Russia was responsible for poisoning former double agent Sergei Skripal and his daughter Yulia using the nerve agent Novichok and that it had sent a...more