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Cracking Down on CJNG: FinCEN’s Alert and OFAC’s Strategic Sanctions on Oil Smuggling

In a significant move to curb illegal activities at the U.S. Southwest border, the Financial Crimes Enforcement Network (FinCEN) issued an alert, on May 1, 2025, concerning oil smuggling from Mexico into the United States,...more

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado...more

FinCEN and BIS Issue Joint Alert on Potential Russian and Belarusian Export Control Evasion

The Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a joint alert on June 28, 2022, warning of evasion attempts by individuals or entities to...more

Russian Oligarch’s Yacht Subject to Forfeiture Based on Alleged Violations of Bank Fraud, Money Laundering, and U.S. Sanction...

Case Highlights the Role of Correspondent Bank Accounts and Circumvention of AML Programs - Court Order Describes Seizure as a “Reckoning” for Atrocities in the Ukraine...more

Second Circuit Says Turkish Halkbank Must Face Criminal Charges In Money Laundering and Iran Sanctions Case

The Second U.S. Circuit Court of Appeals, in a recent 27-page decision, held that Halkbank, the state-owned Turkish lender, cannot claim sovereign immunity under the Foreign Sovereign Immunities Act (“FSIA”) in a money...more

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