FINCast Ep. 19 - The DPRK Sanctions Program
On 20 February 2025, the United States (U.S.) Department of State designated eight international cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The designation of...more
The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....more
In a significant development underscoring the U.S. government’s continued efforts to counter Russia’s destabilizing activities, the U.S. Department of the Treasury recently announced the designation of Gazprombank as a...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control has designated dozens of Russian banks including Gazprombank and issued an alert warning foreign financial institutions of the risk of U.S. sanction for...more
IRS issued Notice 2024-78 on 10/28/24 providing the extension of temporary relief for FATCA Model 1 Financial Institutions (FFI’s) regarding the reporting of U.S. Taxpayer Identification Numbers. This means that the temporary...more
Notice 2023-11, issued in December 2023, provided limited relief to certain foreign financial institutions (FFIs) that were not fully in compliance with the terms of their Model 1 FATCA Intergovernmental Agreement (IGA)....more
The IRS digital asset broker reporting requirements were finalized earlier this year and impact all digital asset (i.e., cryptocurrency and Non-Fungible Tokens or NFTs) transactions beginning January 1, 2025. What do...more
Nearly six months after President Joe Biden signed an executive order (EO) authorizing secondary sanctions against Foreign Financial Institutions (FFIs) conducting or facilitating significant transactions with certain...more
The Biden Administration’s recent expansion of sanctions and export controls to counter Russian aggression will impact non-U.S. financial institutions and increase compliance risks for the business software sector and other...more
January 29, 2024- The U.S. Department of the Treasury issued a finding and notice of proposed rulemaking (NPRM) that identifies an Iraqi bank that serves as a conduit for terrorist financing, as a foreign financial...more
December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more
On December 22, 2023, President Joseph R. Biden, Jr. issued an executive order—”Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities”—that subjects certain foreign financial institutions that...more
The Federal Financial Institutions Examination Council (FFIEC) released the fifth phase of updates to the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (the Manual) on August 2, 2023. While the...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more
Bajo el concepto de “FATCA recíproca”, las instituciones financieras y los corredores deben comenzar a prepararse para asumir mayores y más amplias responsabilidades de reportaje. Como partes interesadas de FATCA, las...more
In a quiet news release delivered on 3/23/22, the IRS updated the FATCA FAQ’s (Q. 22) to inform FATCA Stakeholders that a registration status could be changed to under review with a message indicating “For more information...more
La Ley ALD del 2020 (“AML Act of 2020”) incluye la creación de los “Attachés del Tesoro” (SEC. 6106, designados por el Departamento del Tesoro de los Estados Unidos) y los “Enlaces de la Unidad de Inteligencia Financiera...more
The AML Act of 2020 includes the creation of “Treasury Attachés” (SEC. 6106, appointed by the US Treasury Department) and the “Foreign Financial Intelligence Unit Liaisons” (SEC. 6108, appointed by FinCEN) to be stationed...more
Antes de la aprobación de la LEY AML del 2020 (“AML ACT of 2020”), el Departamento del Tesoro de los EE. UU. y el Departamento de Justicia de los EE. UU. (“DOJ”) tenían la autoridad para citar (“subpoena”) a los bancos...more
Before passage of the AML ACT of 2020 (the “ACT”), The US Department of the Treasury, and the US Justice Department (DOJ) had US legal authority to subpoena foreign banks with US correspondent accounts for related US records...more
On 7 August 2020, eleven Hong Kong officials were added to the Specially Designated Nationals and Blocked Persons List (“SDN List”) of the Treasury Department’s Office of Foreign Assets Control (“OFAC”) pursuant to the...more
On Wednesday, October 14, 2020, the U.S. Department of State (“State”) submitted a report to the U.S. Congress, as required under section 5(a) of the Hong Kong Autonomy Act (“HKAA”), identifying foreign persons materially...more
On October 14, 2020, the U.S. Secretary of State, pursuant to section 5(a) of the Hong Kong Autonomy Act (“HKAA”), submitted a report to Congress identifying foreign persons who are “materially contributing to, have...more
The Situation: On August 7, 2020, the U.S. Department of the Treasury ("Treasury Department") took the first action under the authority of "The President's Executive Order on Hong Kong Normalization" ("HK Normalization EO")...more
President Trump signs law authorizing sanctions on individuals and financial institutions and ends U.S. preferential treatment for Hong Kong. The Hong Kong Autonomy Act authorizes sanctions on foreign financial...more