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National Security Financial Institutions Office of Foreign Assets Control (OFAC)

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

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

Orrick, Herrington & Sutcliffe LLP

FinCEN Calls for Vigilance Against Anticipated Sanction Evasion Attempts

On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions to be vigilant against efforts to evade the expansive and unprecedented sanctions implemented by the United...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

Akin Gump Strauss Hauer & Feld LLP

Ukraine-Russia Crisis: Possible New Sanctions and Export Controls on Russia and Potential Implications for U.S. and Non-U.S....

Key Points - The United States, European Union, United Kingdom and other U.S. allies are currently considering a range of severe economic measures against Russia to impose in the event of a Russian military incursion into...more

K2 Integrity

Treasury Releases 2021 Sanctions Review

K2 Integrity on

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

Skadden, Arps, Slate, Meagher & Flom LLP

US Amends Sanctions Targeting Investments in Securities of Chinese Companies

On June 3, 2021, President Joe Biden issued Executive Order 14032 (EO 14032) amending and, in effect, recasting Executive Order 13959 of November 12, 2020 (EO 13959), which restricted U.S. persons from purchasing and selling...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

Jones Day

FinCEN Issues Guidance on Ransomware Attacks

Jones Day on

The prevalence, sophistication, and severity of ransomware attacks have increased anti-money laundering risks faced by financial institutions both as targets of ransomware attacks and as potential intermediaries in...more

Neal, Gerber & Eisenberg LLP

Potential Sanctions Risks for Facilitating Ransomware Payments

On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory to highlight the sanctions risks associated with ransomware payments related to malicious cyber-enabled...more

Lowndes

Dear Ransomware Victim and Your Accountants, Attorneys and Forensic Specialists: The Government Just Made Your Life Harder

Lowndes on

By now, most everyone knows that ransomware is software that infects your computer system, makes your data irretrievable and usually breaks things along the way. To unlock your system, the bad guys (or girls) demand you pay a...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

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

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Spanish

ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more

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