Pursuant to a sweeping new executive order (EO) issued on June 30, 2025, the Trump administration has lifted virtually all U.S. sanctions targeting Syria, shuttered the Syria sanctions program administered by the Office of...more
7/9/2025
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Reform ,
Syria ,
Trump Administration ,
U.S. Commerce Department
On June 25, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued orders identifying three Mexican financial institutions as being of primary money laundering concern in connection with...more
On May 23, 2025, the Trump administration issued a general license (GL) significantly relaxing the patchwork of restrictions on Syria, long a jurisdiction subject to comprehensive sanctions. This regulatory action followed a...more
In a May 12, 2025, memorandum (the May Memorandum) on focus, fairness and efficiency in the fight against white collar crime, the Department of Justice (DOJ) Criminal Division1 again identified the total elimination of...more
On his first day in office, President Trump signed Executive Order 14157 calling for the designation of certain cartels and transnational criminal organizations (TCOs) as foreign terrorist organizations (FTOs) or specially...more
President Trump has taken the first steps toward fulfilling his promise to reverse the Biden administration’s approach to digital assets by issuing an executive order that establishes a framework for fostering the growth of...more
2/10/2025
/ Biden Administration ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Executive Orders ,
Financial Services Industry ,
FinTech ,
Popular ,
Regulatory Agenda ,
Regulatory Reform ,
Revocation ,
Securities and Exchange Commission (SEC) ,
Stablecoins ,
Technology Sector ,
Trump Administration
In the days before former President Joe Biden left office, the U.S. announced two new rounds of sanctions against Russia, including expansive new sanctions against Russia’s energy sector. According to its press release, the...more
Key Points -
- Political transitions in the West notwithstanding, we expect economic sanctions to remain a key response to geopolitical issues.
- Current sanctions policy priorities are unlikely to shift markedly in...more
1/20/2025
/ China ,
Cybersecurity ,
Data Security ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Export Controls ,
Extraterritoriality Rules ,
Financial Services Industry ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Russia ,
Sanctions ,
UK ,
Whistleblowers ,
White Collar Crimes
On December 26, 2024, the Fifth Circuit merits panel assigned to Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, reinstated a nationwide preliminary injunction enjoining enforcement of the Corporation Transparency Act and...more
12/30/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Vacated
This alert has been updated to reflect FinCEN’s extension of the deadline after the alert was first sent.
On December 23, 2024, after expedited briefing, a three-judge panel of the Fifth Circuit in Texas Top Shop v....more
12/24/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Time Extensions
The Corporate Transparency Act (CTA) and its implementing regulations (Regulations) require entities within its scope (reporting companies) to disclose information, including about their beneficial owners, to the U.S....more
12/16/2024
/ Business Ownership ,
Corporate Counsel ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
Stays ,
Suspended Judgment ,
Unconstitutional Condition
The past weeks and months have brought about tremendous political change in the West, as we move toward a new U.S. administration, a new College of Commissioners in Brussels and a new Polish presidency of the Council of the...more
11/13/2024
/ Capital Markets ,
CFIUS ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Export Controls ,
Extraterritoriality Rules ,
Financial Institutions ,
Middle East ,
National Security ,
Regulatory Requirements ,
Russia ,
Sanctions ,
Tariffs ,
Trump Administration ,
UK ,
Ukraine ,
US Trade Policies ,
Whistleblowers
The Council of the European Union (Council) has updated its EU Best Practices for the Effective Implementation of Restrictive Measures. Published on 3 July 2024, the new version clarifies the threshold for the ownership test...more
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule (the Proposed Rule) to implement certain aspects of the Anti-Money Laundering Act of 2020 (the AML Act), which updated the...more
7/17/2024
/ AML/CFT ,
Anti-Money Laundering ,
Anti-Terrorism Financing ,
Bank Secrecy Act ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Investment Management ,
Popular ,
Proposed Rules ,
Securities and Exchange Commission (SEC)
On April 24, 2024, President Joe Biden signed the 21st Century Peace Through Strength Act (Act) into law. The Act, which is part of a broader law providing supplemental aid to Israel, Taiwan and Ukraine, contains several...more
6/3/2024
/ Anti-Money Laundering ,
Biden Administration ,
CFIUS ,
Economic Sanctions ,
EU ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Statute of Limitations ,
TWEA ,
UK
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more
5/30/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
CFIUS ,
Customer Identification Program (CIP) ,
Financial Institutions ,
FinCEN ,
Policies and Procedures ,
Proposed Rules ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC)
On April 24, 2024, President Joe Biden signed into law a high-profile package of national security legislation (Public Law 118-50). While most press reports focused on the spending elements of the package (appropriating funds...more
5/3/2024
/ Asset Freeze ,
Asset Seizure ,
Economic Sanctions ,
Export Controls ,
International Trade ,
Investors ,
Joe Biden ,
Legislative Agendas ,
National Security ,
New Legislation ,
Russia ,
Ukraine
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
3/26/2024
/ Blocked Person ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
International Trade ,
National Security ,
New Rules ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agenda ,
Regulatory Reform ,
SDN List
The Corporate Transparency Act and its implementing regulations (together CTA) came into effect on January 1, 2024, requiring entities within its scope to disclose information, including about their beneficial owners, to the...more
2/2/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Governance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
New York ,
Popular ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
On October 17, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released two interim final rules to reinforce and expand controls on (a) advanced semiconductors and related computing items (the...more
10/27/2023
/ Bureau of Industry and Security (BIS) ,
China ,
Deadlines ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
Inspections ,
Manufacturers ,
Semiconductors ,
Technology Sector ,
U.S. Commerce Department
The Proposed Rule Aims To Increase Transparency in CVC Mixing -
On October 19, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a notice of proposed rulemaking (Proposal)...more
On October 18, 2023, following the signing of an electoral roadmap between Venezuela’s Unitary Platform and representatives of the Maduro regime, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)...more
In the U.S. Department of Justice’s (DOJ’s) latest effort to promote voluntary self-disclosure of corporate misconduct by companies, Deputy Attorney General (DAG) Lisa Monaco has announced guidance regarding a new safe harbor...more
10/5/2023
/ Acquisitions ,
Compliance ,
Corporate Counsel ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Ethics ,
Mergers ,
New Guidance ,
Safe Harbors ,
Self-Disclosure Requirements ,
Voluntary Disclosure
In a long-awaited decision involving the cryptocurrency “mixer” Tornado Cash, a U.S. district court on August 17, 2023, upheld the broad authority of the Department of the Treasury’s (Treasury’s) Office of Foreign Assets...more
On August 16, 2023, OFAC announced a $660,594 settlement with Construction Specialties Inc. (CS) for alleged violations of the Iranian Transactions and Sanctions Regulations (ITSR). OFAC found that CS’s wholly controlled...more
9/6/2023
/ Anti-Money Laundering ,
Bureau of Industry and Security (BIS) ,
Corporate Governance ,
Department of Justice (DOJ) ,
Employees ,
Enforcement Actions ,
Export Controls ,
Exports ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
U.S. Commerce Department ,
Whistleblowers