FINCast Ep. 19 - The DPRK Sanctions Program
During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more
Background: On Friday November 29, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Sinbad.io (“Sinbad”), alleging that the virtual currency mixer serves as a key money-laundering...more
In two prior posts, this blog tracked the ongoing intrigue of how the various branches of the United States government interact with blockchain and cryptocurrency organizations. We discussed the Wyoming law allowing...more
Tornado Cash, a cryptocurrency mixer, recently suffered two major setbacks in federal regulatory efforts to block its use and prosecute its founders. First, a federal district court threw out a lawsuit challenging the...more
On March 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13551, against a Slovakian national for attempting to facilitate arms deals between Russia...more
On March 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against three entities and two individuals for their roles in illicitly generating revenue to support the government of...more
The Treasury Department’s Office of Foreign Asset Control had another consistent year – not a big year but continued adherence to its enforcement program. At the end of the year, OFAC announced a settlement with TD Bank...more
The Treasury Department’s Office of Foreign Asset Control continues to focus enforcement activities on digital currency companies. This focus is likely to increase given recent comments by Janet Yellen, the head of the...more
It seems almost every day there are reports of new developments under the U.S. sanctions laws. Yet many U.S. companies do not understand the significance of these laws....more
Indictment Again Highlights the Role of Correspondent Banking in Money Laundering - On May 28, 2020, the U.S. Department of Justice (“DOJ”) unsealed a 50-page indictment against 28 North Korean and 5 Chinese bankers...more
In this episode, FIN Principal Daniel Glaser and FIN Vice President David Murray focus on the North Korea Sanctions program. These experts discuss the program's complexities, challenges, and importance in the geopolitical...more
In this quarter, OFAC lifted sanctions on Rusal and other companies following divestment by Oleg Deripaska. Meanwhile, as Venezuela descends into economic and political crisis, the US targeted PdVSA and others to hasten...more
The following is Part II of this article. Secondary Sanctions – Requirements On Non-U.S. Parties That Have No Contacts With the U.S. OFAC also has adopted sanctions that specifically apply to non-U.S. companies and...more
Closing out 2018, OFAC announced its plan to lift sanctions against United Co. Rusal and others, despite bi-partisan opposition from Congress. Simultaneously, OFAC continued to target Russia’s defense and intelligence sectors...more
Happy new year everyone. The government is shut down, but there has already been a flurry of activity in 2019 on the economic sanctions and embargoes front. Here is a summary of where we stand on various sanctions regimes....more
I spent last week in Seoul talking to clients about the latest changes to U.S. trade and sanctions policy (as South Korea is one of Iran’s largest trading partners, it is understandable that some concerns have arisen there in...more
This quarter saw the announcement of sweeping new sanctions against Russia’s billionaire class and their corporate holdings, and included the Trump Administration’s first issuance of sanctions against Russia for meddling in...more
ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more
On Friday, February 23, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) imposed blocking sanctions against one individual, twenty-seven entities and twenty-eight vessels known to have previously...more
The U.S. Office of Foreign Assets Control (OFAC) issued new sanctions targeting the shipping industry for dealings involving North Korea. The sanctions include the designation of 56 companies and vessels involved in...more
As we discussed further at length, the U.S. and nations around the world have recently sought to implement and impose harsh economic sanctions programs against North Korea to pressure Pyongyang into ceasing its development...more
Sanctions compliance is challenging because of the changing nature of sanctions regulations and individuals identified as Specially Designated Nationals. With each new administration, foreign policy priorities are usually...more
The Trump Administration has been active on the sanctions front as a means of asserting United States foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late,...more