The U.S. government issued guidance on October 14, 2022, emphasizing that the United States is “prepared to use its broad targeting authorities against non-U.S. persons” who continue to trade with Russia sanctions targets,...more
As Russia’s invasion of Ukraine persists, with no end currently in sight, the United States continues to issue increasingly punishing economic sanctions and export controls targeting Russia, most recently aiming at the...more
5/17/2022
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Entities ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Professional Services Companies ,
Russia ,
Ukraine
Russia’s invasion into Ukraine in February 2022 has prompted the United States and its allies, including the United Kingdom, the European Union, and others, to issue substantial international trade restrictions such as...more
4/21/2022
/ Banks ,
Belarus Sanctions ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Trade Relations ,
Trade Restrictions ,
UK ,
Ukraine
Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more
3/22/2022
/ Anti-Money Laundering ,
Anti-Terrorism Financing ,
Bank Secrecy Act ,
Belarus ,
Bureau of Industry and Security (BIS) ,
Convertible Virtual Currencies (CVCs) ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
FinCEN ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Russia ,
SDN List ,
SWIFT ,
U.S. Treasury ,
UK ,
Ukraine
On February 21, 2022, Russian President Vladimir Putin unilaterally recognized the Luhansk and Donetsk regions in Eastern Ukraine (Covered Regions) as independent states. Thereafter, Mr. Putin authorized a full-scale invasion...more
3/3/2022
/ Banking Sector ,
Bureau of Industry and Security (BIS) ,
CAPTA List ,
Economic Sanctions ,
Export Controls ,
Exports ,
Financial Institutions ,
Financial Transactions ,
FinTech ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Sovereign Debt ,
SWIFT ,
Ukraine
On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering, terrorism...more
On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released guidance on sanctions compliance for the digital currency industry, the agency’s most detailed guidance to date on...more
10/20/2021
/ Compliance ,
Corporate Counsel ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Financial Services Industry ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Regulatory Oversight ,
Risk Assessment ,
SDN List ,
Strict Liability ,
U.S. Treasury ,
Virtual Currency
Agency’s Focus on Cryptocurrency and Blockchain Continues -
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an updated advisory to “highlight the sanctions...more
10/5/2021
/ Crypto Exchanges ,
Currency Exchange ,
Cyber Attacks ,
Cybersecurity ,
Economic Sanctions ,
Enforcement Actions ,
Guidance Update ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
U.S. Treasury ,
Virtual Currency