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
1/26/2024
/ AML/CFT ,
Audits ,
Civil Monetary Penalty ,
Compliance ,
Criminal Penalties ,
Crude Oil ,
Cryptocurrency ,
Due Diligence ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
International Emergency Economic Powers Act (IEEPA) ,
Liability ,
Maritime Transport ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Risk Assessment ,
Sanction Violations
As noted in our prior alerts (concerning OFAC’s September 9, 2022 preliminary guidance and October 31, 2022 follow-on FAQ clarifying the applicability of the impending price cap policy) the U.S. Department of the Treasury’s...more
On September 20th, 2022, the Securities and Exchange Commission (“Commission”) entered a settled order (“Order”) against the wealth management arm of a global financial services firm (“Firm”) for its failure to protect...more
On September 27, 2022, the Securities and Exchange Commission (“Commission”) entered into a series of settled orders (“Orders”) against 15 broker-dealers and one affiliated investment adviser for widespread failures by the...more
10/4/2022
/ Broker-Dealer ,
Compliance ,
Electronic Communications ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Penalties ,
Policies and Procedures ,
Recordkeeping Requirements ,
Securities ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934