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Reporting Requirements Office of Foreign Assets Control (OFAC)

King & Spalding

Biden Administration Issues Proposed Rule Targeting “Connected Vehicles” Tied to China or Russia

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The Proposed Rule imposes substantial new reporting, diligence, and compliance obligations for companies in the automotive supply chain - On September 26, 2024, the U.S. Department of Commerce’s Bureau of Industry and...more

Whiteford

Client Alert: OFAC Update: Reporting, Procedures and Penalties Rule Changes Effective November 7, 2024

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The Department of the Treasury’s Office of Foreign Assets control (OFAC) issued a final rule amending specific reporting and procedural regulations effective November 7, 2024. OFAC published the interim final rule on May 10,...more

Locke Lord LLP

OFAC’s Extended Recordkeeping Requirements From 5 to 10 Years

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On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an Interim Final Rule amending its Reporting, Procedures, and Penalties Regulations under 31 C.F.R. Part 501. This...more

Foley Hoag LLP

OFAC Publishes Both Interim Final Rule Extending Recordkeeping Requirements and Comment Request Regarding its Information...

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OFAC issued an interim final rule extending OFAC’s recordkeeping requirements from 5 years to 10 years, to comport with the corresponding statute of limitations extension. OFAC also published a request for public comment...more

Baker Botts L.L.P.

OFAC Extends Recordkeeping Requirements for All Sanctions Programs

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In an era of active U.S. sanctions policy, it is not uncommon to see the Office of Foreign Assets Control (“OFAC”) issue a notice changing U.S. sanctions – promulgating a new sanctions program or updating the designation of a...more

Morrison & Foerster LLP

OFAC Extends Recordkeeping Requirements from Five to 10 Years; Issues Paperwork Reduction Act Request for Comments

On September 11, 2024, OFAC announced its Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years. The Interim Final Rule (IFR) was published in the Federal Register on September 13, 2024. Public...more

Locke Lord LLP

REPO Act Requires Financial Institutions to Report Russian Sovereign Assets

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On July 23, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) issued a new reporting requirement following the enactment of the Rebuilding Economic Prosperity and Opportunity for Ukrainians...more

Davis Wright Tremaine LLP

Deadline Approaching for Filing 2024 OFAC Annual Report of Blocked Property

The annual September 30 deadline for submitting the Annual Report of Blocked Property (ARBP) to the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) is fast approaching. Under federal regulations, "all U.S....more

Seward & Kissel LLP

Compliance Flash: OFAC Announces New Reporting Requirement for Financial Institutions Under the REPO for Ukrainians Act

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The supplemental appropriations legislation signed into law on April 24, 2024 enacted numerous high-profile provisions addressing aspects of U.S. foreign policy and national security, including provisions that broaden and...more

Foodman CPAs & Advisors

OFAC RPPR Regla Final Interina

El 5/8/2024, la OFAC enmendó y emitió una Regla Final Interina sobre las Regulaciones de Reportes, Procedimientos y Sanciones (“RPPR”) que establece requisitos estándar de presentación de reportes y mantenimiento de registros...more

Foodman CPAs & Advisors

OFAC RPPR Interim Final Rule

On 05/08/2024, OFAC amended and issued an interim final rule on the Reporting, Procedures and Penalties Regulations (RPPR) which sets forth standard reporting and recordkeeping requirements and license application and other...more

White & Case LLP

The Shadow Financial System

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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

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - June 2024

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On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (IFR), effective August 8, 2024, that updates the Reporting, Procedures, and Penalties Regulations....more

Hogan Lovells

OFAC issues interim final rule amending blocked property and other reporting requirements

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The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an interim final rule set to take effect August 8, 2024, which amends the Reporting, Procedures, and Penalties Regulations (the “Regulations”)...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Revamps Reporting Requirements

Key Points - On May 10, 2024, OFAC issued an IFR that would amend its Reporting, Procedures and Penalties Regulations (RPPR) at 31 C.F.R. Part 501 to, among other things, modify certain reporting requirements pertaining to...more

Sheppard Mullin Richter & Hampton LLP

No More Postcards to OFAC in 2024: Unpacking OFAC’s New Reporting Procedures

On May 10, 2024, The Office of Foreign Assets Control (OFAC) has released a new proposed rule which would make significant changes to OFAC’s standard reporting, record-keeping, and license applications under U.S. sanction...more

Akin Gump Strauss Hauer & Feld LLP

Congress Extends Statute of Limitations for Sanctions and Certain Other National Security Programs from 5 to 10 Years and...

While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more

ArentFox Schiff

Beverage & Food Industry in 2024: 10 Hot Topics for Beverage & Food Industry Founders, Investors, and Executives

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2023 was a pivotal year for the beverage and food industry globally, creating new categories of winners and losers across the board. With a full year of operations largely relieved of pandemic-era restrictions, restaurant...more

ArentFox Schiff

Legal Considerations for GCs and CFOs in the Fashion and Retail Industry in 2024

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The fashion and retail industry experienced another year of considerable change in 2023. As advancements in artificial intelligence (AI) spurred innovation within the industry, consumers and regulators worldwide called for...more

Paul Hastings LLP

Public Company Watch: January 2024

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In the January Public Company Watch, we cover key issues impacting public companies, including navigating the 2023 20-F season, updated SEC guidance related to confidential treatment applications, the Delaware Court of...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - December 2023

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TRADE TIP OF THE MONTH: New Companies Have More Time To Report Ownership- The Treasury Department’s Financial Crimes Enforcement Network issued a final rule in late November to delay the deadline for newly created...more

K2 Integrity

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

K2 Integrity on

Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

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The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

The Volkov Law Group

Reminder to file your 2023 Annual Report of Blocked Property: Due date September 30, 2023

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On September 22, 2023, the U.S. Department of Treasury Office of Foreign Assets Control (“OFAC”) issued its “Reminder to file your 2023 annual report of Blocked Property,” noting that entities or persons subject to the...more

Torres Trade Law, PLLC

Post-G7 Sanctions – Putting the G7 Leaders Voiced Concerns into Action

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In May 2023, the leaders of the United States, Canada, France, Germany, Italy, Japan, and the United Kingdom gathered in Hiroshima, Japan, for the annual G7 summit. The symbolic significance of these global leaders meeting in...more

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