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OFAC Issues Warning to Financial ‎Institutions & Insurers That ‎Provide Maritime Services in the ‎Mediterranean, Red Sea and...

Iran and Syria Sanctions and Embargos On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued updated guidance to remind maritime support service providers that the...more

FinCEN Proposes AML/CFT ‎Augmentation Rule

On June 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) intended to strengthen and modernize U.S. financial institutions’...more

REPO Act Requires Financial Institutions to Report Russian Sovereign Assets

On July 23, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) issued a new reporting requirement following the enactment of the Rebuilding Economic Prosperity and Opportunity for Ukrainians...more

FUNDamentals: FinCEN [Re]Proposes Anti-Money Laundering Rules for Investment Advisers

On February 13, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) proposed a new rule that would require federal investment advisers to add Bank Secrecy Act (“BSA”) type anti-money...more

U.S. Issues Warning to Foreign ‎Financial Institutions That Assist Russia’s War Machine

On December 22, 2023, President Biden issued new Executive Order (“EO”) 14114, amending EO 14024 and EO 14068. The new EO grants the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) authority to...more

OFAC Russia Related ‎Sanctions Update ‎to Extend Deadline for Transactions With Sanctioned ‎Financial ‎Institutions

On October 25, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published General Licenses (“GL”) 8H related to the‎ ‎Russian Harmful Foreign Activities ‎Sanctions Regulations, 31 CFR Part...more

Protecting High Value Bank Accounts – ‎Options to Increase FDIC Insurance Limits and Trust ‎Solutions

The recent collapses of Silicon Valley Bank (“SVB”) and Signature Bank—followed by the bailout of Credit Suisse—have led depositors to look for ways to protect their deposits in excess of the Federal Deposit Insurance...more

OFAC Russia Related Sanctions Update: ‎August 2022 #2

On August 19 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended Russia-related General License (“GL”) 38A (GL 38A) and issued a new GL (GL 50) related to the Russian Harmful Foreign...more

OFAC Russia Related Sanctions Update: ‎‎July 2022‎ #3

On July 22, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) (1) issued two new Russia-related General Licenses (“GL”) (GL 45 and GL 46), (2) published two new FAQs (FAQ 1071 and FAQ...more

OFAC Russia Related Sanctions Update: ‎July 2022‎

On June 28, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued five new General Licenses (“GL”) (GL 39, GL 40, GL 41, GL 42, and GL 43), released a new determination prohibiting gold...more

OFAC Russia Related Sanctions Update: ‎June 2022‎ #3

On June 14, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License (“GL”) 8C (replacing GL 8B), which extends the temporary wind down period to December 5,...more

OFAC Russia Related Sanctions Update: ‎June 2022‎

On June 2, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License (“GL”) 25B, GL 36, GL 37, and GL 38....more

Russia Response to Western Sanctions – Nationalization

Russia first invaded Ukraine in February 2014. This latest invasion started on February 24, ‎‎2022. As of mid-April 2022, over 750 international companies have publicly announced plans ‎to curtail or shut down operations...more

FDIC Launches Brokered Deposit Resource Webpage and ‎Provides Guidance for Expedited Processing of Notices for ‎Designated...

Effective April 1, 2021, the Federal Deposit Insurance Corporation (“FDIC”) launched a “Brokered Deposit” bankers’ resource web page, concurrently with the effective date of its final rule ‎‎(the “Rule”)‎ to modernize the...more

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