In its first application of the policy on voluntary self-disclosures (“VSDs”) in connection with mergers and acquisitions (“M&A”), on June 16, 2025, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”)...more
6/24/2025
/ Acquisitions ,
Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Mergers ,
Office of Foreign Assets Control (OFAC) ,
Private Equity ,
Regulatory Requirements ,
Reporting Requirements ,
Self-Disclosure Requirements ,
U.S. Commerce Department ,
Voluntary Disclosure
Effective February 20, 2025, the United States Designated Eight Cartels and Transnational Criminal Organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs)....more
2/25/2025
/ Anti-Money Laundering ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Financial Crimes ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Terrorist Organizations ,
U.S. Treasury
On February 5, 2025, President Trump's nominee to lead the Justice Department (the "Department"), Pamela Bondi, was confirmed by the Senate to serve as the U.S. Attorney General. Bondi immediately took action to reshape the...more
Compliance with sanctions regimes has been a priority for debt markets. Amid rising geopolitical tensions, the stakes for lenders and borrowers are higher than ever -
Intensifying geopolitical tensions and the US...more
9/5/2024
/ Banking Sector ,
Biden Administration ,
Borrowers ,
Debt Market ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
International Emergency Economic Powers Act (IEEPA) ,
Lenders ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Authority ,
Sanctions
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
6/18/2024
/ Anti-Money Laundering ,
CFTC ,
Cross-Border Transactions ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
International Trade Commission (ITC) ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Recordkeeping Requirements ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
UK ,
Virtual Currency
On October 15, 2021, the US Department of the Treasury’s Office of Foreign Assets Control ("OFAC") issued a brochure to promote sanctions compliance in the virtual currency industry (the "Guidance")1 and updated two related...more
On 2 March 2021, the United States and European Union ("EU") imposed coordinated sanctions in response to the poisoning and imprisonment of Russian opposition politician Aleksey Navalny (and the related US determination that...more
On January 10, 2020, the President signed a new Executive Order (EO), "Imposing Sanctions With Respect to Additional Sectors of Iran," targeting Iran's construction, mining, manufacturing, and textiles industries. On the same...more
1/15/2020
/ Aluminum Sales ,
Blocked Person ,
Construction Industry ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Iran ,
Iran Sanctions ,
Manufacturers ,
Metals ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Steel Industry ,
Textiles ,
Trump Administration
On August 2, 2019, the United States announced the imposition of additional sanctions on the Russian Federation under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act)....more
8/8/2019
/ Banks ,
Biological-Weapons ,
Bonds ,
Bureau of Industry and Security (BIS) ,
Chemical Warfare ,
Chemical Weapons ,
Economic Sanctions ,
Export Controls ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trump Administration
On May 8, 2019, following Iran's announcement that it intends to suspend certain nuclear proliferation-related commitments under the Joint Comprehensive Plan of Action (JCPOA), the United States issued a new Executive order...more
5/14/2019
/ Blocking Sanctions ,
Blocking Statutes ,
CAPTA List ,
China ,
Economic Sanctions ,
EU ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
France ,
Germany ,
IFCA ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Metals ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Prohibited Transactions ,
SDN List ,
Steel Industry ,
Suspensions ,
Trump Administration ,
UK ,
Waivers
On January 28, 2019, the Department of the Treasury's Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) on the List of Specially Designated Nationals and Blocked Persons (SDN List). PdVSA...more
2/11/2019
/ Banking Sector ,
Blocked Person ,
Coercion ,
Dispute Resolution ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
GATT ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Petroleum ,
SDN List ,
Trade Restrictions ,
Trump Administration ,
Venezuela ,
WTO
On January 27, 2019, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) lifted sanctions imposed on En+ Group plc (En+), UC Rusal plc (Rusal), and JSC EuroSibEnergo (ESE), removing these entities from...more
TABLE OF CONTENTS:
Executive Summary -
Developments and Trends in Policy and Enforcement
- US Department of the Treasury
- The Office of Foreign Assets Control
- Treasury's Financial Crimes Enforcement Network
-...more
1/22/2019
/ Anti-Money Laundering ,
Banks ,
Broker-Dealer ,
BSA/AML ,
CFTC ,
Civil Monetary Penalty ,
Compliance ,
Cuba ,
Customer Due Diligence (CDD) ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
FDIC ,
FFIEC ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
FinCEN ,
FinTech ,
FRB ,
Guilty Pleas ,
Information Sharing ,
Investment Banks ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nicaragua ,
North Korea ,
NYDFS ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Piling-On ,
Russia ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Sudan ,
Suspicious Activity Reports (SARs) ,
Syria ,
Terrorism Funding ,
U.S. Treasury ,
Ukraine ,
Venezuela