As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more
4/3/2025
/ Anti-Money Laundering ,
Cartels ,
Civil Liability ,
Criminal Liability ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Financial Institutions ,
International Emergency Economic Powers Act (IEEPA) ,
Mexico ,
Money Laundering ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Terrorist Organizations ,
Trump Administration
The US State Department has made its first round of designations pursuant to Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists,”...more
2/27/2025
/ Anti-Corruption ,
Corporate Counsel ,
Criminal Prosecution ,
Economic Sanctions ,
Executive Orders ,
Foreign Entities ,
Foreign Investment ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Terrorism Funding
Shortly after President Trump’s second inauguration, his executive branch took steps to further one of his signature promises: securing the southern border. While these actions primarily impact immigration laws, several...more
As the world prepares for the change of administration in January, current government officials and industry experts convened at the New York Forum on Economic Sanctions to reflect on enforcement trends in 2024, and to...more
12/10/2024
/ Anti-Money Laundering ,
Banks ,
Bureau of Industry and Security (BIS) ,
Cryptocurrency ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
National Security ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Self-Disclosure Requirements ,
Technology ,
Voluntary Disclosure
2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more
1/12/2024
/ Bureau of Industry and Security (BIS) ,
CFTC ,
Compliance ,
Economic Sanctions ,
Enforcement ,
European Anti-Fraud Office (OLAF) ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
Suspicious Activity Reports (SARs) ,
Voluntary Disclosure ,
Whistleblowers
The past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen...more
12/5/2023
/ Acquisitions ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Corporate Crimes ,
Corporate Misconduct ,
Cryptocurrency ,
Cyber Crimes ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Intellectual Property Protection ,
Investigations ,
Mergers ,
National Security ,
Recidivism ,
Remediation ,
Sanction Violations ,
Self-Disclosure Requirements ,
Terrorist Financing ,
Voluntary Disclosure ,
Whistleblowers
A recent OFAC enforcement action against MidFirst Bank highlights the five essential components of an effective sanctions compliance program that will serve to mitigate exposure in the event of a violation:
Senior...more
At a sanctions conference held in Washington D.C. on May 5, government officials, practitioners and corporations highlighted the government’s broadening focus on anti-corruption enforcement, across more traditionally siloed...more
5/17/2022
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Arms Export Control Act ,
Cryptocurrency ,
Cybersecurity ,
Economic Sanctions ,
Enforcement ,
Environmental Social & Governance (ESG) ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
ITAR ,
New Regulations ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Russia ,
Ukraine
Amid the escalating conflict in Ukraine and concerns of Russian cyber threats to the United States, President Joe Biden recently signed a $1.5 trillion government spending deal with serious cybersecurity reporting obligations...more
3/17/2022
/ Critical Infrastructure Sectors ,
Cyber Attacks ,
Cyber Threats ,
Cybersecurity ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
Joe Biden ,
Russia ,
Ukraine
“Know your customer” is a bed rock principle of anti-money laundering and sanctions compliance programs, but it’s not always easy, particularly as more sophisticated and aggressive players have taken the field in recent...more
3/16/2022
/ Anti-Money Laundering ,
Biden Administration ,
Compliance ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Executive Orders ,
FinTech ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Shell Corporations ,
U.S. Commerce Department ,
U.S. Treasury ,
Ukraine
Over the past week, the Biden Administration has announced unprecedented sanctions and export controls against Russia in response to its unprovoked invasion of Ukraine. As the State Department pledges an additional $350...more
On June 3, 2021, the White House issued a memorandum announcing anti-corruption as a core national security interest. The memorandum explains that, “[c]orruption threatens United States national security, economic equity,...more
6/10/2021
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Biden Administration ,
China ,
Corporate Transparency Act ,
Cybersecurity ,
Economic Sanctions ,
Enforcement ,
Enforcement Actions ,
Export Controls ,
Foreign Agents Registration Act (FARA) ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities and Exchange Commission (SEC)