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
On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued three orders (the “Orders”) pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, designating three...more
President Donald Trump announced that his imposed 25% tariffs on imports from Mexico and Canada will take effect today, March 4, 2025, at 12:01 a.m. EST....more
U.S. President Donald Trump issued Executive Order 14157 (the EO) on Jan. 20, 2025, calling for the designation of drug cartels and other foreign organizations as foreign terrorist organizations (FTOs) or specially designated...more
Upon being sworn in on February 5, 2025, Attorney General Pamela Bondi immediately issued memoranda reorienting national security enforcement resources of the U.S. Department of Justice (“DOJ”) to focus on addressing illegal...more
In response to the tariffs imposed by President Trump on Canada, Mexico, and China on February 1, 2025 under the International Emergency Economic Powers Act (IEEPA), each of those three countries has indicated it plans to...more
On his first day in office, President Donald Trump signed an executive order that initiates the process of designating certain drug cartels as foreign terrorist organizations. The executive order is primarily focused on...more
The first two days of the new Trump administration were marked by pronouncements that portend short-run uncertainty about the tariff environment. Although President Trump’s past statements had led many people to expect he...more
While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more
On April 24, 2024, President Biden signed into law a long-debated $98 billion foreign aid and national security legislative package (the “Act”) providing funds for Israel, Taiwan, and Ukraine, and authorizing new sanctions...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
The Corporate Transparency Act (31 USC §5336) goes into effect January 1, 2024. Under the Act, most LLCs (and other entities) will need to supply basic personal identification data regarding their “beneficial owners” to...more
Financial Crimes Enforcement Network (FinCEN) remains committed to combating money laundering, in all forms, in connection with the banking and financial systems. To this end, on June 30, 2021, FinCEN issued new...more
On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more