On September 30, 2022, the Office of Foreign Assets Control (OFAC) published compliance guidance for instant payment systems. The guide highlights the need for emerging payment technology companies to assess their sanctions...more
Updated as of February 25, 2022 -
Key Takeaways of EU and UK Recent Actions Against Russia and Ukraine Breakaway Regions -
The EU adopted the first tranche of sanctions restrictions targeting financial institutions, other...more
On February 4, the Department of the Treasury published a study on the facilitation of money laundering and terrorist financing through the art trade. Among other considerations, the report discussed the risks of financial...more
2/28/2022
/ Anti-Money Laundering ,
BSA/AML ,
Cryptocurrency ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Money Laundering ,
Non-Fungible Tokens (NFTs) ,
Terrorist Financing ,
U.S. Treasury
Last Friday, the Office of Foreign Assets Control (OFAC) published more targeted guidance for digital asset companies related to compliance with sanctions and best practices for mitigating risks. This guide comes on the heels...more
10/22/2021
/ Compliance ,
Cryptocurrency ,
Data Management ,
Digital Currency ,
Economic Sanctions ,
Financial Institutions ,
Financial Services Industry ,
Geolocation ,
IP Addresses ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Regulatory Oversight ,
Risk Management ,
Strict Liability ,
Virtual Currency
This week has been a week of significant foreign policy action. Today, President Biden issued a new Executive Order imposing tough sanctions on Russia for its interference in the U.S. 2020 presidential election, as well as...more
4/16/2021
/ Biden Administration ,
Cyber Attacks ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Russia ,
Sanctions ,
SolarWinds ,
Sovereign Debt ,
U.S. Treasury ,
US State Departments
Since the U.S. Government determined that Russia interfered in the 2016 election, movement around Russia sanctions policy has been vigorous, if not unidirectional. In 2016, the United States implemented twice sanctions...more
2/9/2018
/ CAATSA ,
Defense Sector ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
National Security ,
Privatization ,
Russia ,
Sanctions ,
Secondary Sanctions ,
US Department of State
Russian President Vladmir Putin has directed his government to develop a state-backed cryptocurrency, according to a Financial Times report published on January 2nd. A Putin advisor says that the “Crypto-rouble” could be used...more
1/11/2018
/ Anonymity ,
Anti-Money Laundering ,
Bitcoin ,
Blockchain ,
Criminal Investigations ,
Cross-Border Transactions ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
Russia ,
Vladimir Putin
Late last week, Congressional intelligence committees reportedly received some information from the U.S. Financial Crimes Enforcement Network (FinCEN) related to investigations into Russia’s attack on the 2016 U.S....more
5/24/2017
/ Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Donald Trump ,
Financial Institutions ,
FinCEN ,
Government Investigations ,
Money Laundering ,
Patriot Act ,
Political Campaigns ,
Presidential Elections ,
Russia ,
Suspicious Activity Reports (SARs)
On January 10, 2017, Senate Republicans and Democrats introduced bi-partisan legislation called the “Countering Russian Hostilities Act of 2017,” which would impose broad sanctions on Russia. The Act would codify the...more
1/13/2017
/ Amended Legislation ,
Barack Obama ,
Bipartisan Agreement ,
Cyber Attacks ,
Cyber Sanctions ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Legislative Agendas ,
Office of Foreign Assets Control (OFAC) ,
Pending Legislation ,
Presidential Elections ,
Russia ,
Trump Administration ,
Vladimir Putin
In late May, The Russian Federation issued its first sovereign bond since the Ukraine crisis in 2014. The sole organizer of the bond is VTB Capital, an arm of VTB Bank, Russia’s second largest financial institution. Both VTB...more