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
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
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
Scoring a victory for the Securities and Exchange Commission in its efforts to qualify digital tokens as securities, a New Hampshire federal court ruled this week that tokens sold by LBRY Inc., known as LBC, are securities...more
Voyager Digital Assets, Inc., a leading cryptocurrency brokerage and lending platform, filed for Chapter 11 bankruptcy protection on July 5, 2022 in the Southern District of New York following a recent financial crisis...more
On May 19, 2022, the Department of Justice (“DOJ”) announced significant clarifications to its policy on charging Computer Fraud and Abuse Act (“CFAA”) violations that give some comfort to cyber security consultants who...more
6/9/2022
/ Computer Fraud and Abuse Act (CFAA) ,
Cyber Crimes ,
Cybersecurity ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Institutions ,
Good Faith ,
Hackers ,
Popular ,
SCOTUS ,
Van Buren v United States
A vulnerability so dangerous that Cybersecurity and Infrastructure (CISA) Director Jen Easterly called it “one of the most serious [she’s] seen in [her] entire career, if not the most serious” arrived just in time for the...more
In keeping with the United States government’s expanding scrutiny of cryptocurrency markets, the DOJ recently announced the creation of a National Cryptocurrency Enforcement Team (the “NCET”). The NCET endeavors to add a...more
10/27/2021
/ Anti-Money Laundering ,
CFTC ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
U.S. Treasury ,
Virtual Currency
On Tuesday, the U.S. Department of Treasury’s Office of Foreign Asset Control (“OFAC”) issued an updated advisory warning all ransomware victims that if they succumb to ransomware demands and pay foreign actors who are...more
9/24/2021
/ Cybersecurity ,
Cybersecurity Information Sharing Act (CISA) ,
FBI ,
Guidance Update ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Sanctions ,
SDN List ,
Strict Liability ,
U.S. Treasury
On the heels of the First American enforcement action and settlement, this week, the SEC announced a settlement with Pearson plc in connection with a 2018 cyber breach. The SEC disclosed that Pearson, a London-based...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)
The cyber landscape is changing once again, in terms of impact, policy and potential exposure. In the wake of the Colonial Pipeline hack, the Biden administration released a long-awaited Executive Order intended to strengthen...more
5/18/2021
/ Biden Administration ,
Critical Infrastructure Sectors ,
Cyber Attacks ,
Cybersecurity ,
Department of Energy (DOE) ,
Energy Regulatory Commission ,
Enforcement ,
Executive Orders ,
Federal Contractors ,
Hackers ,
National Security ,
Pipelines ,
Popular ,
Proposed Regulation ,
Regulatory Oversight