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Recent OFAC and DOJ Activity Signals Potential New Era of Control-Based Sanctions Enforcement

U.S. sanctions enforcement is evolving to adopt a “control” analysis similar to the analysis employed by the European Union and United Kingdom based on a recent major enforcement action by the U.S. Department of the...more

Drug Cartel Designations as FTOs Increase Financial Institutions’ Civil Liability Risks Under the Antiterrorism Act

The Anti-Terrorism Act (ATA) created a federal cause of action enabling U.S. nationals injured by reason of an "act of international terrorism" to sue those allegedly responsible for their injuries; it was later amended to...more

Q4 2020: Latin America Enforcement Review

As 2020 drew to a close, enforcement authorities throughout the United States and the Americas continued to investigate fraud, corruption, and other misconduct across the region. Below, we highlight some developments from...more

G-7 Officials Release Report On Cybersecurity In The Financial Sector

n October 13, 2017, finance ministers and central bank governors of the Group of Seven (the “G-7”) released a report entitled Fundamental Elements for Effective Assessment of Cybersecurity for the Financial Sector. The G-7...more

New Rules of the Cyber Road: Federal Banking Regulators Seek Comment by January 17, 2017 on Proposed Cybersecurity Regulations

Continuing the trend of recent years, cybersecurity has remained at the top of the regulatory agenda for several federal and state agencies. For financial institutions, keeping track of the dizzying array of proposed...more

FFIEC Releases Answers To FAQs About Cybersecurity Assessment Tool

On October 17, 2016, the Federal Financial Institutions Examination Council (“FFIEC” or the “Council”) released a set of answers to frequently asked questions about its cybersecurity assessment tool (the “CAT”). The FFIEC, an...more

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