All Things Investigations: Episode 30 - The Convergence of ABC, AML and Export Controls with Mike Huneke and Jan Dunin-Wasowicz
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...more
On July 3, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had amended entries for a multitude of entities sanctioned under the Treasury’s Russian Harmful Foreign...more
In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. ...more
The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more
Companies are increasingly choosing not to pay ransom for ransomware and extortionware due to the growing associated risks. In fact, a recent report by crypto-crime analyst firm Chainalysis found that payments to threat...more
With the ever-increasing use of sanctions as a foreign policy tool (or weapon), sanctions compliance has taken on greater importance than ever. Moreover, as countries increase extraterritorial applications of their sanctions,...more
On April 28, 2022, the New York State Department of Financial Services (DFS) issued guidance on the use of blockchain analytics for virtual currency businesses licensed under 23 NYCRR part 200 (also known as a BitLicense) or...more
With Russia’s invasion of Ukraine last week, we saw a swift response by the U.S. beginning with President Biden’s Executive Order 14024 (“The EO”) and followed quickly by the Office of Foreign Assets Control’s (“OFAC”) severe...more
Back in July, we took a look at the enforcement actions for the first half of 2021 issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Today’s post – the second half of our OFAC 2021 Year...more
On Oct. 15, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) published sanctions compliance guidance for the virtual currency industry. OFAC acknowledged that virtual currencies are playing an...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
The Bank Secrecy Act (BSA) and parts of the U.S. Patriot Act’s Office of Foreign Asset Control (OFAC) requirements have seemingly similar goals: to prevent money laundering and the funding of terrorist activities. Yet a...more
Apollo Settles Alleged Sanctions Violations: Aircraft Lessors Pay Attention - The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has broad delegated authority to administer and enforce the...more
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has broad delegated authority to administer and enforce the sanctions laws and related sanctions programs of the United States. As a key...more
Virtual currencies like Bitcoin and Ethereum have spawned many types of businesses that need banking services. Many banks "de-risk" -- do not provide banking services -- to these businesses. Many virtual currency...more
On July 5, 2017, Bureau Van Dijk, a sponsor of my blog, conducted a webinar on the importance of beneficial ownership information to corporate compliance functions....more
The opening of Cuba to greater commercial and financial activity offers many possibilities for U.S. financial institutions but, with those possibilities, comes a responsibility to meet the complex compliance challenges that...more