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National Security Financial Institutions Economic Sanctions

Buchalter

Expanded Export Controls and Sanctions Require Heightened Compliance for All Industries

Buchalter on

A Changed Regulatory Environment – Companies who think that U.S. export controls and sanctions do not apply to their products and channels of trade should reassess that position. As an example, approximately US$1.1 billion in...more

Ankura

Navigating OFAC Sanctions Risks in the Digital Realm: IP Addresses and Effective Controls

Ankura on

In today's digital landscape, sanctions enforcement has become a critical concern for Financial Institutions (FIs). The borderless nature of cyberspace can make it difficult to monitor and regulate activities that may breach...more

Snell & Wilmer

United States Announces Largest Round of Sanctions Since the Start of Russia’s War in Ukraine

Snell & Wilmer on

The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...more

American Conference Institute (ACI)

Navigating U.S. Sanctions and Export Control Restrictions

Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more

Oberheiden P.C.

National Security in the Age of Blockchain

Oberheiden P.C. on

Blockchain presents unprecedented challenges around national security. This is true not only for the federal government, but also for businesses in the private sector. From cross-border transactions involving cryptocurrency...more

Oberheiden P.C.

OFAC Compliance: Developing and Implementing an Effective Sanctions Compliance Program

Oberheiden P.C. on

Financial institutions and companies that are subject to oversight from the Office of Foreign Assets Control (OFAC) need to prioritize compliance. OFAC has become increasingly active in recent years, and it is devoting...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

Skadden, Arps, Slate, Meagher & Flom LLP

In Coordinated Action, US Authorities Increase Russia-Related Restrictions and Warn About Evasion Risks

Through a series of coordinated actions in May 2023, the United States launched a whole-of-government effort to expand and strengthen enforcement of its sanctions campaign against Russia as the conflict in Ukraine continues...more

American Conference Institute (ACI)

Compliance measures to address sanctions enforcement: ‘the new FCPA’

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

Morgan Lewis

Russian Law Restricts Compliance with US National Defense Authorization Act

Morgan Lewis on

Russia President Vladimir Putin signed the federal law, “On Amendments to the Federal Law ‘On Measures of Influence (Counteraction) on Unfriendly Actions of the United States of America and Other Foreign States,’” on May 1,...more

McGuireWoods LLP

DOJ Launches “Task Force KleptoCapture” in Response to Russian Invasion

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Last week, the U.S. Department of Justice (DOJ) announced the launch of an aggressive interagency law enforcement task force, Task Force KleptoCapture. The Task Force represents another U.S. enforcement initiative in response...more

Morrison & Foerster LLP

Justice Department Announces Launch of Task Force “KleptoCapture” focused on Russia-related Sanctions Violations

On March 2, 2022, the U.S. Department of Justice announced the launch of Task Force KleptoCapture, an interagency law enforcement task force dedicated to enforcing the unprecedented sanctions, export, and other measures taken...more

Wiley Rein LLP

DOJ Announces Launch of KleptoCapture Task Force in Response to Russia’s Invasion of Ukraine

Wiley Rein LLP on

On March 2, 2022, Attorney General Merrick B. Garland announced the launch of a new interagency task force, the KleptoCapture Task Force, focused on enforcing the recent U.S. financial sanctions and other economic...more

Morgan Lewis

Update: US Sanctions on Russia Have Extraterritorial Implications

Morgan Lewis on

In connection with recent Russia-related sanctions issued by the US government, organizations face a variety of issues when navigating the questions of who and what transactions may be subject to the reach of these sanctions....more

K2 Integrity

Treasury Releases 2021 Sanctions Review

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On October 18, 2021, the U.S. Department of the Treasury released the 2021 Sanctions Review (“the Review”), which delineates Treasury’s framework for employing economic sanctions and provides key recommendations on...more

Akin Gump Strauss Hauer & Feld LLP

New Requirements for UAE Companies Under Updated Targeted Financial Sanctions Guidance

Through updated guidance, the UAE has introduced a significant change to how it administers sanctions regimes—expanding its focus from a limited implementation of multilateral sanctions to more broadly imposing its own...more

WilmerHale

Biden: The Fight Against Foreign and Transnational Corruption Is a National Security Interest

WilmerHale on

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

Skadden, Arps, Slate, Meagher & Flom LLP

Sanctions Remain Key; Implementation of Sweeping Anti-Money Laundering Legislation Begins

Sanctions - The Biden administration has made clear that economic sanctions will continue to be an important U.S. foreign policy tool and has initiated a comprehensive review of current sanctions policies and practices....more

Bilzin Sumberg

OFAC Issues Regulatory Advisory Warning Against Facilitating Ransomware Payments

Bilzin Sumberg on

On October 1, 2020, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an “Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” The Advisory, which does not carry the...more

Hogan Lovells

Treasury Department issues ransomware guidance in response to significant uptick in ransomware attacks

Hogan Lovells on

In response to the significant rise in ransomware attacks since the start of the COVID-19 pandemic and just in time for Cybersecurity Awareness Month, the Department of the Treasury’s Financial Crimes Enforcement Network...more

BCLP

DOJ Issues Policy for Export Control and Sanctions Enforcement (IRB No. 580)

BCLP on

On December 13, 2019, the US Department of Justice (DOJ) issued an update to its 2016 guidance regarding enforcement in export control and sanctions investigations of businesses.  The updated policy now offers voluntary...more

K&L Gates LLP

D.C. Circuit Upholds Foreign Banks’ Contempt for Noncompliance with U.S. Subpoenas in North Korea Sanctions Investigation

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On August 6, the D.C. Circuit Court of Appeals unsealed its partly redacted decision upholding a civil contempt order against three foreign banks that refused to comply with a subpoena from U.S. authorities to produce bank...more

Ballard Spahr LLP

D.C. Circuit Rules in Favor of Broad Reach of Patriot Act Subpoenas

Ballard Spahr LLP on

On August 6, the U.S. Court of Appeals for the District of Columbia kept in place $50,000-per-day fines on three Chinese banks—whose identities are redacted—for refusing to comply with subpoenas issued by the Department of...more

Dechert LLP

U.S. Announces Second Round of Sanctions on Russia for Chemical Weapons Violations

Dechert LLP on

The U.S. State and Treasury Departments announced that a second round of sanctions will be imposed against Russia pursuant to the Chemical and Biological Weapons Control Act of 1991 (“CBW Act”). The most notable new measure...more

Akin Gump Strauss Hauer & Feld LLP

Recent U.S. Sanctions Designations Create Additional Risks for Companies Doing Business with Venezuela

• OFAC recently added a Moscow-based Russian-Venezuelan joint venture bank, Evrofinance Mosnarbank (“Evrofinance”), to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) for engaging in sanctions...more

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