The Committee on Foreign Investment in the United States (CFIUS) has taken another significant step in transforming from a limited jurisdiction interagency committee that primarily reviewed voluntary filings into a body with...more
On February 28, 2024, President Biden issued Executive Order 14117, calling for new regulations to prohibit or restrict transactions that enable countries of concern to access sensitive U.S. personal and government data. The...more
President Biden issued an executive order on December 22, 2023 targeting evasion of U.S. sanctions on Russia. Executive Order 14,114: Authorizes sanctions on foreign financial institutions (“FFIs”) determined to have...more
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued a final rule (the Access Rule) regarding access to and use of beneficial ownership information (BOI) maintained by FinCEN....more
On October 17, 2023, the U.S. Commerce Department’s Bureau of Industry Security (BIS) issued revised export control regulations intended to impede China’s efforts to obtain and produce advanced semiconductors. The new steps...more
The Biden administration has issued a long-awaited executive order authorizing regulation of U.S. investments in Chinese semiconductor, quantum computing and AI companies. The Treasury Department published a corresponding...more
The Committee on Foreign Investment in the United States (CFIUS) reportedly observed limits on its authority in a recent case to examine and potentially disturb foreign investment transactions for national security reasons....more
The United States has strengthened economic sanctions and export controls targeting Russia, following through on commitments made at a G7 summit this month. The EU and UK also plan to substantially expand measures targeting...more
On April 19, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a $300 million civil penalty on Seagate Technology LLC, a U.S. supplier of data-storage products. BIS found that...more
In light of Russia’s invasion of Ukraine and intensifying strategic competition with China, the U.S. government is prioritizing enforcement of export controls and economic sanctions in unprecedented ways. We expect higher...more
Effective February 5, 2023, a coalition of G7 countries, Australia, and the European Union have generally forbidden service providers to provide certain services relating to the maritime transport of certain Russia-origin...more
The Financial Crimes Enforcement Network of the U.S. Treasury Department (“FinCEN”) issued a Notice of Proposed Rulemaking (the “Proposed Access Rule”) on December 15, 2022 to implement the second key provision of the...more
Effective December 5, 2022, a coalition of G7 countries, Australia, and the European Union have generally forbidden service providers to provide certain services relating to the maritime transport of Russia-origin crude oil...more
12/6/2022
/ Australia ,
Economic Sanctions ,
EU ,
Exports ,
G7 ,
General Licenses ,
Maritime Transport ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia
This fall the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published a final rule (the “Rule”), effective January 1, 2024, to implement beneficial ownership reporting requirements included in the...more
On October 7, 2022, the U.S. Commerce Department’s Bureau of Industry Security (“BIS”) released new export control regulations (the “New Regulations”) that intensify and complicate U.S. and non-U.S. companies’ international...more
The President has issued the first executive order providing formal direction to the Committee on Foreign Investment in the United States (“CFIUS”) on the risks that it should consider in its examination of foreign investment...more
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned the popular decentralized virtual currency mixer Tornado Cash on August 8, 2022, continuing the U.S. government’s efforts to target...more
The Uyghur Forced Labor Prevention Act (the “Uyghur Act”) came into effect on June 21, 2022. As we described previously, the Uyghur Act establishes a rebuttable presumption that goods mined, produced, or manufactured, in...more
As part of its continuing response to Russia’s ongoing hostilities in Ukraine, the United States recently imposed additional sanctions and export controls targeting Russia...more
The Financial Crimes Enforcement Network (“FinCEN”) recently issued an advisory urging financial institutions (including certain cryptocurrency businesses) to implement controls to help detect proceeds of foreign public...more
4/27/2022
/ Bribery ,
BSA/AML ,
Cryptocurrency ,
Economic Sanctions ,
Embezzlement ,
Extortion ,
Financial Institutions ,
FinCEN ,
Foreign Official ,
Misappropriation ,
Money Laundering ,
New Guidance ,
Offshore Funds ,
Public Corruption ,
Ransomware ,
Russia ,
Shell Corporations ,
Suspicious Activities ,
Suspicious Activity Reports (SARs)
The United States, the European Union and the United Kingdom recently imposed new Russia-related sanctions in response to Russia’s continued hostilities in Ukraine...more
The United States and its allies continue to ramp up pressure on Russia and Belarus in response to Russia’s continued hostilities in Ukraine. In this alert, we describe the latest export, import, and investment bans and...more
The Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (the “Proposed Rule”) in late January seeking public comment on a proposed pilot program that would expand financial institutions’...more
Two recent guilty pleas involving a cryptocurrency exchange serve as a reminder to all money services businesses (“MSBs”)—including those ostensibly located outside the United States but that conduct business there—of the...more
3/4/2022
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BitMEX ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Department of Justice (DOJ) ,
FinCEN ,
Guilty Pleas ,
Know Your Customers ,
Money Services Business ,
Office of Foreign Assets Control (OFAC)
Two recent guilty pleas involving a cryptocurrency exchange serve as a reminder to all money services businesses (“MSBs”)—including those ostensibly located outside the United States but that conduct business there—of the...more