Financial institutions operating in New York — including New York state licensed banks, trust companies, private bankers, savings banks, savings and loan associations, branches of foreign banks, check cashers, and money...more
In response to Burma’s peaceful and competitive elections in November 2015, on May 18, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) further eased U.S. sanctions against Burma (Myanmar). These...more
5/24/2016
/ Burma ,
Economic Sanctions ,
Exports ,
Financial Institutions ,
Foreign Investment ,
General Licenses ,
Myanmar ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SDN List ,
State-Owned Enterprises
In the wake of the Panama Papers controversy, the U.S. government has taken major steps this month to promote financial transparency. First, the Financial Crimes Enforcement Network (FinCEN) finalized its proposed rule issued...more
5/17/2016
/ Anti-Money Laundering ,
Banks ,
Customer Due Diligence (CDD) ,
Due Diligence ,
Economic Sanctions ,
EU ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Ownership Requirements ,
Popular ,
Transparency ,
White Collar Crimes
On March 31, 2016, the U.K. launched the new Office of Financial Sanctions Implementation (OFSI) within HM Treasury. OFSI, which assumes the financial sanctions responsibilities previously carried out by HM Treasury’s Asset...more
On March 15, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) announced regulatory amendments that further eased U.S....more
On January 27, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) further eased U.S. sanctions and export control regulations...more
On January 16, 2016, the International Atomic Energy Agency verified that Iran had complied with the nuclear-related technical aspects of the Joint Comprehensive Plan of Action it had to complete before the first phase of...more
1/28/2016
/ Banking Sector ,
Economic Sanctions ,
EU ,
Foreign Entities ,
IAEA ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List
While economic sanctions against Iran, Russia and Cuba have dominated the headlines over the past year, sanctions remain a dynamic component of U.S. foreign policy on other fronts. In 2015, President Barack Obama issued three...more
1/23/2016
/ Burundi ,
Cross-Border Transactions ,
Cuba ,
Cyber Attacks ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Human Rights ,
Iran Sanctions ,
Obama Administration ,
Russia ,
Venezuela
Editor’s note: This article includes news developments through January 18, 2016.
The historic agreement that the P5+1 (the United States, the United Kingdom, France, China, Russia and Germany) and the European Union...more
Last year, financial institutions continued to settle in record numbers with federal and state criminal and civil authorities in areas including benchmark interest rate manipulation, economic sanctions and anti-money...more
Virtual currency businesses saw increased oversight by U.S. regulators in 2015, and continued interest by federal and state authorities is expected as regulation evolves. Two recent developments in this arena are particularly...more
This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases and enforcement trends, including developments in U.S. Foreign Corrupt Practices Act enforcement; the introduction of...more
11/4/2015
/ Accomplice Liability ,
Anti-Corruption ,
Asia ,
Attorney-Client Privilege ,
Bribery ,
China ,
Criminal Prosecution ,
Cross-Border ,
Cross-Border Transactions ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Government Investigations ,
India ,
Internal Investigations ,
Libor ,
Market Manipulation ,
Non-Resident Aliens ,
OECD ,
Public Officials ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
South Korea ,
Tax Evasion ,
Thailand ,
UK ,
Whistleblower Protection Policies ,
Whistleblowers ,
Work-Product Doctrine
On September 21, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) amended their respective Cuba regulations to...more
9/30/2015
/ Airlines ,
Bureau of Industry and Security (BIS) ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Financial Transactions ,
Information Technology ,
Internet Service Providers (ISPs) ,
Licenses ,
Office of Foreign Assets Control (OFAC) ,
Physical Presence Test ,
Sanctions ,
Telecommunications ,
U.S. Commerce Department ,
Vessels
On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) that would impose certain anti-money laundering (“AML”) requirements on...more
9/11/2015
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Currency Transaction Reports (CTR) ,
FinCEN ,
Investment Adviser ,
Know Your Customers ,
NPRM ,
OCIE ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
Editor’s note: This article was updated on July 23, 2015, to Editor’s note: This article was updated on July 23, 2015, to reflect certain additional information in U.N. Security Council Resolution 2231.
On July 14, 2015,...more
7/21/2015
/ Aircraft ,
Aircraft Equipment ,
Automotive Industry ,
Banks ,
Crude Oil ,
Energy Sector ,
EU ,
Financial Institutions ,
Implementation Day ,
Imports ,
International Atomic Energy Agency ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Metals ,
Non-US Entities ,
Nuclear Power ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
P5+1 Nations ,
SDN List ,
Shipping ,
Software ,
Transition Day ,
United Nations
On April 1, 2015, President Barack Obama issued an executive order (the Order) authorizing sanctions against foreign individuals or entities found to be responsible for certain malicious cyberattacks. Under the Order, the...more
Following closely on the heels of the reinstated reporting requirements for inbound and outbound direct investment involving U.S. entities, the U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) has announced...more
In response to the protracted crisis in Ukraine, the Obama administration authorized traditional and innovative economic sanctions against Russian and Ukrainian persons through Executive Orders 13660, 13661, 13662 and 13685....more
For financial institutions, customer due diligence may become tougher and costlier in 2015 if the Financial Crimes Enforcement Network's (FinCEN) latest proposed rule is finalized in its current form. On July 30, 2014, FinCEN...more
Since the 1960s, the United States has maintained an embargo on Cuba that in many respects is the most comprehensive set of economic and trade restrictions on any country. On January 16, 2015, amendments to regulations issued...more
1/21/2015
/ Amended Regulation ,
Banking Sector ,
Bureau of Industry and Security (BIS) ,
Cuba ,
Embargo ,
Executive Orders ,
Exports ,
Imports ,
Obama Administration ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Telecommunications ,
Trade Relations ,
Travel Permits
On April 25, 2014, following a meeting of the G7 in which member countries broadly agreed to take further action against Russia in response to political violence and unrest in Ukraine, U.S. officials imposed sanctions against...more
On April 28, 2014, as part of its evolving response to the situation in Ukraine, the White House announced new restrictions on exports of “high-technology” items and services to Russia and Crimea. The announcement also...more
In a further sign of the broadening of U.S. restrictions relating to Russia because of the situation in Ukraine, the United States has taken steps to limit trade with Russia in U.S.-origin goods and services that are...more
Last week the United States and European Union continued to ramp up economic sanctions related to events in Ukraine and Russia. Because the most recent round of sanctions is likely to have a much broader reach, entities must...more
In the wake of Sunday’s referendum in Crimea to secede from Ukraine, the United States and the European Union imposed economic sanctions on several high-level public officials in Ukraine and Russia. Please see our alert dated...more