News & Analysis as of

Evasion Customer Due Diligence (CDD) Economic Sanctions

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Orrick, Herrington & Sutcliffe LLP

FinCEN and Commerce Dept. urge monitoring of Russian export control evasion attempts

On May 19, FinCEN and the Department of Commerce’s Bureau of Industry and Security (BIS) issued a supplemental joint alert urging continued vigilance for potential Russian export control evasion attempts...more

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