News & Analysis as of

Regulatory Agenda Office of Foreign Assets Control (OFAC)

Eversheds Sutherland (US) LLP

Horizon Scanner Financial Crime - US developments - September 2024

The booklet summarises key financial crime related legal and regulatory changes expected over the next 18 months to 2 years, as well as providing electronic links to key resources. Key developments: - US Supreme Court...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

Torres Trade Law, PLLC

Application of the Substantial Transformation Principle in the Context of U.S. Sanctions

Torres Trade Law, PLLC on

The practice of determining an item’s country of origin (“COO”) and utilizing the principal of “substantial transformation” to help make this determination is likely a familiar concept for many U.S. importers in the context...more

White & Case LLP

The Shadow Financial System

White & Case LLP on

The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

Skadden, Arps, Slate, Meagher & Flom LLP

New BIS Rule Imposes Stringent Export Control Restrictions Targeting Large Number of OFAC-Sanctioned Parties

On March 21, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule amending the Export Administration Regulations (EAR) by imposing “end user” export control restrictions against...more

Jenner & Block

Client Alert: White House Executive Order Seeks to Protect Americans’ Sensitive Personal Data and US Government-Related Data in...

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On February 28, 2024, President Biden issued Executive Order 14117 on Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern (the EO). The EO empowers...more

Fenwick & West LLP

U.S. Imposes New Sanctions on Russia and Warns of Substantial Risks of Doing Business in Russia

Fenwick & West LLP on

The United States imposed a new round of economic sanctions and export restrictions on Russia today, marking the second anniversary of Russia’s invasion of Ukraine and following the death of Russian opposition leader, Alexei...more

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

Jenner & Block on

As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – December 2023 Update

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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

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - December 2023

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – October 2023 Update

Bass, Berry & Sims PLC on

October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading...more

A&O Shearman

OFAC Suspends Certain U.S. Sanctions Targeting Venezuela with New and Amended General Licenses

A&O Shearman on

On October 18, 2023, the United States announced the suspension of certain sanctions related to Venezuela through the issuance of new and revised general licenses. The Office of Foreign Assets Control (OFAC) of the U.S....more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - October 2023 # 4

Troutman Pepper on

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Bradley Arant Boult Cummings LLP

Navigating OFAC Settlements: An In-Depth Analysis of Sanctions Violations and Compliance Lessons

The Office of Foreign Assets Control’s (OFAC) settlements in the second half of 2023 serve as cautionary tales for organizations navigating the complex landscape of international sanctions. These cases offer valuable insights...more

Dorsey & Whitney LLP

Executive Order 14105 on Outbound Investment in China and Proposed Rule

Dorsey & Whitney LLP on

On August 9, President Biden issued Executive Order 14105 (“EO 14105”) on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern. EO 14105 significantly reshapes...more

Cadwalader, Wickersham & Taft LLP

Take Two: The Lummis-Gillibrand Crypto Assets Bill 2.0

On July 12, Senator Kirsten Gillibrand, a Democratic senator from New York who sits on the Senate Banking Committee, and Senator Cynthia Lummis, a Republican senator from Wyoming who sits on the Agriculture Committee, joined...more

WilmerHale

Parameters of New US Outbound Investment Regime Begin to Emerge

WilmerHale on

Following a series of public reports, the United States appears close to announcing a new regulatory process to scrutinize US “outbound” investment to countries presenting national security challenges. ...more

Sheppard Mullin Richter & Hampton LLP

NFT Regulatory Issues – a 2022 Review and 2023 Preview

Despite the minimal regulatory enforcement actions against blockchain game companies and NFT issuers, now is NOT the time to become complacent about regulatory issues. As indicated below, many U.S. agencies are increasing...more

BakerHostetler

Ethereum Moves to PoS; Firms Launch Crypto, NFT Initiatives; EO Crypto Energy Impact Report Published; Crypto Addressed by OFAC,...

BakerHostetler on

Ethereum Network Completes Transition to Proof of Stake Consensus - After years of development and delays, Ethereum’s long-awaited “merge” occurred this week, changing the network’s consensus mechanism from proof-of-work...more

Perkins Coie

OFAC Takes Action Against Virtual Currency Tornado Cash in Novel Application of Sanctions Authorities

Perkins Coie on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), on August 8, 2022, sanctioned virtual currency mixer Tornado Cash. OFAC alleged that it had been “used to launder more than $7 billion worth of...more

White & Case LLP

US Expands Sanctions to Include Russia's Central Bank and Direct Investment Fund

White & Case LLP on

On 28 February 2022, the US imposed sanctions prohibiting transactions involving Russia's Central Bank and blocking Russia's Direct Investment Fund. In addition, the US issued implementing regulations for EO 14024....more

Sheppard Mullin Richter & Hampton LLP

Are You Ready for Web3.0 and the Legal Issues it Will Bring?

Blockchain is one of the most significant new technologies since the internet. It has ushered in what has been referred to as Web3.0. Some of the most popular applications of this technology include NFTs and metaverses. ...more

Proskauer - Blockchain and the Law

Treasury Department Steps Up Its Counter-Ransomware Efforts and Simultaneously Issues New Sanctions Compliance Guidance for...

Recently, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury Department, released a report on ransomware trends stating that during the first half of 2021, 68 different ransomware variants...more

Skadden, Arps, Slate, Meagher & Flom LLP

A Growing Focus on Cybersecurity

President Joe Biden has been fulfilling his promise to prioritize cybersecurity in his administration: He issued several cybersecurity-related executive orders, and federal regulators under his administration also have turned...more

Cozen O'Connor

OFAC Amends and Reissues More Comprehensive Somalia Sanctions Regulations

Cozen O'Connor on

In a final rule issued last week, the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) has amended and reissued the Somalia Sanctions Regulations, which can be found in 31 C.F.R. Part 551....more

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