In conjunction with the Group of Seven (G7) leaders meeting in Italy earlier this month, key jurisdictions issued the latest in a series of coordinated economic restrictions on Russia in light of its invasion of Ukraine in...more
7/1/2024
/ Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Foreign Financial Institutions (FFI) ,
Foreign Trade Regulations ,
G7 ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Technology ,
UK ,
Ukraine
On April 24, 2024, President Biden signed into law H.R. 815, an emergency appropriations package billed as authorizing $95 billion in foreign aid to Ukraine and Israel (the Act). While the Ukraine and Israel aid provisions...more
4/30/2024
/ Appropriations Bill ,
Biden Administration ,
China ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Federal Budget ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Israel ,
Russia ,
TikTok ,
UK ,
Ukraine
On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more
Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more
10/16/2023
/ Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Good Faith ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Self-Reporting ,
Serious Fraud Office (SFO) ,
U.S. Commerce Department ,
U.S. Treasury ,
UK ,
Voluntary Disclosure
On May 19, in response to Russia’s ongoing invasion of Ukraine, the United States, in coordination with allies and partners, announced new sanctions restrictions and export controls targeting Russia’s evasion networks,...more
6/5/2023
/ Asset Freeze ,
Avoidance ,
Banking Sector ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Energy Sector ,
EU ,
Executive Orders ,
Export Controls ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
The rise of ransomware attacks has prompted the international community to explore a range of approaches to deter these attacks, including the use of sanctions, the further development and instantiation of norms governing...more
6/2/2023
/ Blocked Person ,
Compliance ,
Cyber Threats ,
Cybersecurity ,
Data Protection ,
Data Security ,
Economic Sanctions ,
Malware ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Risk Mitigation ,
Risk-Based Approaches ,
Russia ,
SDN List
The Office of Financial Sanctions Implementation (OFSI) has updated its ‘enforcement and monetary penalties for breaches of financial sanctions’ guidance, which was last updated in June 2022. ...more
3/23/2023
/ Business Ownership ,
Change of Ownership ,
Compliance ,
Control Test ,
Due Diligence ,
Economic Sanctions ,
Enforcement ,
Financial Conduct Authority (FCA) ,
Guidance Update ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Strict Liability ,
UK
The emergence of digital assets has brought new risks and challenges, including the potential exploitation of the technology to facilitate financial crime.
The U.S. Department of Justice has committed to work with its law...more
1/10/2023
/ Bank Secrecy Act ,
Civil Liability ,
Criminal Liability ,
Cryptoassets ,
Department of Justice (DOJ) ,
Digital Assets ,
Economic Sanctions ,
Enforcement Priorities ,
Fraud ,
Securities Fraud ,
Wire Fraud
Western sanctions against Russia have continued to broaden substantially into new areas of trade, especially in the energy sector. Policymakers in Washington DC, Brussels, London and other allied capitals also continue to...more
3/18/2022
/ Asset Freeze ,
Belarus ,
Blocked Entities ,
Blocked Person ,
Cryptocurrency ,
Economic Sanctions ,
EU ,
Export Controls ,
General Licenses ,
Imports ,
Most-Favored Nations ,
Russia ,
Trade Relations ,
Trade Restrictions ,
UK ,
Ukraine
Top EU Court Rules on the EU Blocking Regulation Against US Sanctions for the First Time -
On December 21, 2021, the Court of Justice of the European Union (CJEU), sitting as a “Grand Chamber” (a formation used, among...more
On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more
9/24/2021
/ Advisory Opinions ,
AML/CFT ,
Anti-Money Laundering ,
Compliance ,
Cryptocurrency ,
Currency Exchange ,
Cybersecurity Information Sharing Act (CISA) ,
Economic Sanctions ,
FinCEN ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Russia ,
SDN List ,
U.S. Treasury ,
Virtual Currency
On June 3, 2021, President Biden issued a National Security Memorandum establishing the fight against corruption both at home and abroad as a core United States national security interest and directing the development of a...more
6/9/2021
/ Anti-Corruption ,
Anti-Money Laundering ,
Biden Administration ,
Compliance ,
Corporate Governance ,
Cross-Border Transactions ,
Economic Sanctions ,
Financial Institutions ,
Foreign Corporations ,
Government Agencies ,
National Security ,
NDAA ,
Patriot Act ,
Presidential Memorandum ,
Transparency
On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more
5/7/2021
/ Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Compliance ,
Department of Justice (DOJ) ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Money Transfer ,
Moneygram ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Pass-Through Entities ,
SAP SE ,
SDN List ,
Settlement ,
Subsidiaries ,
Third-Party Risk ,
Voluntary Disclosure
The COVID-19 pandemic has had profound economic and political effects over the past several months. Increasingly, those effects have led a number of US policymakers, US allies, and others to question certain US sanctions...more
5/5/2020
/ Coronavirus/COVID-19 ,
Economic Downturn ,
Economic Sanctions ,
Human Rights ,
Importers ,
Imports ,
Iran Sanctions ,
Medical Equipment ,
Office of Foreign Assets Control (OFAC) ,
Personal Protective Equipment ,
Trade Relations ,
U.S. Treasury
On December 13, 2019, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) issued a revised policy regarding voluntary disclosure of export control and sanctions violations by business organizations...more
12/27/2019
/ Amended Regulation ,
Arms Export Control Act ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Cooperation ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Enforcement Guidance ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
ITAR ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Standards ,
Voluntary Disclosure ,
Willful Blindness ,
Willful Misconduct
On August 5, 2019, President Donald Trump signed Executive Order 13884, Executive Order Blocking Property of the Government of Venezuela (EO 13884). EO 13884 is designed to further increase pressure on the Nicolás Maduro...more
8/7/2019
/ Blocked Person ,
Citgo ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
Trump Administration ,
U.S. Treasury ,
Venezuela
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more
7/29/2019
/ Anti-Money Laundering ,
BSA/AML ,
Cuba ,
Customer Due Diligence (CDD) ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
FinCEN ,
Human Trafficking ,
Iran ,
Magnitsky Act ,
Nicaragua ,
North Korea ,
Russia ,
Sudan ,
Trump Administration ,
Venezuela ,
Virtual Currency
On March 27, 2019, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with US-based Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd....more
4/2/2019
/ Black & Decker ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Foreign Subsidiaries ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Settlement ,
Subsidiaries
Yesterday, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) pursuant to Executive Order 13850, adding the state-owned Venezuelan oil company to its...more
On November 28, the Treasury Department sanctioned two Iran-based individuals for exchanging bitcoin into Iranian rials on behalf of malicious cyber actors involved in the SamSam ransomware scheme. Notably, this action marks...more
12/3/2018
/ Bitcoin ,
Crypto Exchanges ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Iran ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
SDN List ,
U.S. Treasury
On Tuesday, May 8, President Trump announced that the United States would end its participation in the Joint Comprehensive Plan of Action (JCPOA), signed by the Permanent Five Members of the Security Council plus Germany...more