On June 25, 2025, FinCEN announced its first orders under the 2024 FEND Off Fentanyl Act, finding that three Mexican financial institutions—CIBanco S.A. Institución De Banca Multiple (“CIBanco"), Intercam Banco S.A.,...more
In a historic first, the US Department of the Treasury’s Financial Crimes Enforcement Network recently published orders prohibiting transactions with covered Mexico-based financial institutions. On June 30, 2025, the US...more
On June 25, 2025, FinCEN issued its first orders under the 2024 FEND Off Fentanyl Act (FOFA), imposing special measures against three Mexican financial firms—CIBanco S.A., Institución de Banca Múltiple (CIBanco), Intercam...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) took a historic step in combating the fentanyl crisis on June 25, 2025, by exercising, for the first time, the expansive authorities granted...more
On June 25, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued orders identifying three Mexican financial institutions as being of primary money laundering concern in connection with...more
2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more
On May 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 14059, against four individuals involved in the fentanyl trade, along with two related...more
2022 was an unprecedented year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). While the sweeping new U.S. sanctions imposed against Russia and Belarus in unparalleled...more
Recent developments in the European Union (EU) as well as political demands indicate that the criminal prosecution of sanctions violations in the EU will be further intensified and possibly even centralized:...more
Jüngere Entwicklungen in der Europäischen Union („EU“) sowie politische Forderungen deuten darauf hin, dass die strafrechtliche Verfolgung von Sanktionsverstößen in der EU weiter intensiviert und gegebenenfalls sogar...more
Since its last enforcement action against Banco Popular in late May, OFAC has been quiet on the enforcement front. Notwithstanding its silence, OFAC has been managing a robust and complex coordinated economic sanctions...more
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more
This quarter, companies around the globe prepared to exit Iran-related business in the wake of U.S. sanctions snap-back. Meanwhile, OFAC provided a path to relief to designated Russian entities, extending several deadlines...more
The first six months of the Trump Administration saw several notable developments for US sanctions, with particular implications for Russia and Iran. The Administration also declared a shift in US policy toward Cuba. ...more