Two recent OFAC enforcement actions highlight real-world challenges that financial institutions and other companies may face in their efforts to implement an effective sanctions compliance program....more
On May 27, OFAC announced a civil settlement with a Puerto Rico-based bank in connection with apparent violations of the Venezuela Sanctions Regulations. While the settlement amount of $255,938 is a fraction of the...more
Following reports of alleged atrocities committed by Russian forces in parts of Ukraine, the United States and the European Union have announced significant new economic sanctions aimed at further cutting off Russia from...more
4/7/2022
/ Biden Administration ,
CAPTA List ,
Economic Sanctions ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Military Conflict ,
Russia ,
Ukraine ,
Vladimir Putin
Increased defense spending and assistance to the Ukrainian government in Kyiv grabbed many of the headlines regarding President Biden’s fiscal year 2023 budget. However, funding requests for key functions within the...more
4/1/2022
/ Anti-Money Laundering ,
Defense Sector ,
Economic Sanctions ,
Enforcement Actions ,
Federal Budget ,
FinCEN ,
Foreign Policy ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine
As the conflict in Ukraine grinds on, sanctions against Russia have continued to tighten. Since we published our Clients & Friends Memo last week, available here, President Biden issued Executive Order (“EO”) 14068 of March...more
3/21/2022
/ Anti-Corruption ,
Biden Administration ,
Economic Sanctions ,
Exports ,
Financial Transactions ,
Foreign Policy ,
Foreign Trade Regulations ,
Imports ,
Luxury Goods ,
Russia ,
Ukraine ,
Vladimir Putin
It should come as no surprise that the crushing sanctions imposed on Russia in recent weeks will be met with efforts to evade their impact. From Russian firms starved for U.S. dollars to oligarchs starved for that new villa...more
3/17/2022
/ Biden Administration ,
Bitcoin ,
Blockchain ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Enforcement Priorities ,
Financial Services Industry ,
Financial Transactions ,
Military Conflict ,
Russia ,
Ukraine
It happened in an instant. Almost overnight Russia, the world’s eleventh-largest economy, was transformed from an important player in global financial markets – both as a destination for investment and a source of capital –...more
Moscow’s invasion of Ukraine has – as promised by US President Joseph R. Biden and other world leaders – provoked “unprecedented” economic sanctions against Russia. The United States, the United Kingdom, and the European...more
3/10/2022
/ Biden Administration ,
Blocked Person ,
Economic Sanctions ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Infrastructure ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
SDN List ,
SWIFT ,
Ukraine ,
Vladimir Putin
I. A Growing Risk -
The United States, along with the United Kingdom and European Union, has increasingly wielded economic sanctions against major commercial actors and financial transactions, sometimes roiling global...more
3/3/2021
/ AML/CFT ,
Blocking Statutes ,
Derivatives ,
Economic Sanctions ,
EU ,
Financial Transactions ,
Global Market ,
ISDA ,
Popular ,
UK ,
White Collar Crimes
On December 31, 2015, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued regulations implementing Executive Order 13694 of April 1, 2015, which authorized the imposition of economic sanctions on...more