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Economic Sanctions FinCEN Bank Secrecy Act

Holland & Knight LLP

FinCEN Advisory Highlights Iran Sanctions Evasion Red Flags

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The U.S. Department of the Treasury's (Treasury) Financial Crimes Enforcement Network (FinCEN), published the FinCEN Advisory on the Iranian Regime's Illicit Oil Smuggling Activities, Shadow Banking Networks, and Weapons...more

Oberheiden P.C.

10 Important Facts About FinCEN’s Whistleblower Program

Oberheiden P.C. on

The Financial Crimes Enforcement Network (FinCEN) is one of a handful of federal authorities that have adopted whistleblower programs focused on facilitating enforcement in hard-to-target areas. While FinCEN focuses its...more

The Volkov Law Group

Mitigating Risks of “Interacting” with Cartels and TCOs

The Volkov Law Group on

We have some new vernacular to bring into the compliance arena — companies need to address risks of interacting with cartels and transnational criminal organizations (TCOs).  Companies need to understand the laws used to...more

K2 Integrity

The Challenge of Transparency in Preventing Financial Crime: Navigating Financial Integrity in a Changing Risk Landscape

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The landscape of financial crimes is constantly evolving, and the concept of transparency is being fundamentally challenged. A dynamic, innovative approach is imperative to preserve and shape the future of financial...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - October 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Jones Day

Federal Agencies Highlight Benefits of Self-Disclosure, Emphasize Enforcement of Trade Violations in Tri-Seal Compliance Note

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In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

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The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

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On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Congress Fixes Major Hole In Treasury’s Nascent Whistleblower Program While Expanding Its Scope To Sanctions Evaders

Takeaways: •The Treasury Whistleblower Program now provides for guaranteed awards of 10% to 30% of the government recovery in covered actions- •The Treasury Whistleblower Program has been expanded to include not just tips...more

Ballard Spahr LLP

Russia Sanctions Evasion and Commercial Real Estate: An Alert

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On January 25, the Financial Crimes Enforcement Network (“FinCEN”) issued an “Alert on Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites, Oligarchs, and Their Proxies” (the “Alert”). The Alert...more

Orrick, Herrington & Sutcliffe LLP

FinCEN alert covers potential CRE investments by sanctioned Russians

On January 25, the Financial Crimes Enforcement Network (FinCEN) issued an alert to financial institutions on potential investments in the U.S. commercial real estate sector by sanctioned Russian elites, oligarchs, their...more

The Volkov Law Group

Bittrex’s Sanctions and AML Violations: The Importance of Compliance Controls for the Cryptocurrency Industry (Part II of II)

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In parallel with the Office of Foreign Assets Control (“OFAC”), the Financial Crimes Enforcement Network (“FinCEN”) settled with Bittrex, Inc. (“Bittrex”), a cryptocurrency exchange that allows users to trader virtual assets,...more

Ballard Spahr LLP

OFAC and FinCEN Settle with Bittrex in Regulators’ First Parallel Virtual Currency Enforcement Actions

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The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...more

Venable LLP

Treasury Doubles Up Enforcement Efforts Against Noncompliant Crypto Platforms

Venable LLP on

​​​​​​​The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced yesterday that they had reached settlements for over $24 million and $29 million,...more

Ballard Spahr LLP

Russian Sanctions: FinCEN Provides Red Flags for Potential Evasion Attempts

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On March 7, the Financial Crimes Enforcement Network (FinCEN) issued an alert “advising all financial institutions to be vigilant against potential efforts to evade the expansive sanctions and other U.S.-imposed restrictions...more

Perkins Coie

Recent Developments in US Sanctions and Export Controls Targeting Russia

Perkins Coie on

Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more

McGuireWoods LLP

FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions including Use of Virtual...

McGuireWoods LLP on

The Financial Crimes Enforcement Network (FinCEN) has issued an alert encouraging all financial institutions to be “vigilant” against efforts by their customers to evade recent sanctions and other restrictions imposed by the...more

Harris Beach Murtha PLLC

Federal Financial Regulators Issue Warnings About Russian Sanction Evasion Attempts

With the imposition of sweeping new sanctions on Russia and Belarus following the invasion of Ukraine, federal financial regulators are issuing warnings about efforts to evade these actions. On Monday, March 7, 2022, the...more

Herbert Smith Freehills Kramer

FinCEN Warns of Russian Sanctions Evasion Attempts and Provides Guidance for Increased Vigilance

On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) of the Treasury Department published guidance on increased vigilance for potential Russian sanctions evasion attempts. The FinCEN Alert follows the...more

Ballard Spahr LLP

To Pay or Not to Pay? Evolving Legal Considerations With Ransomware

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1. Overview of the regulatory issues facing companies—and cyber insurers—that may need to respond to ransomware emanating from a threat actor or group with potential ties to entities on federal lists.- The U.S. Treasury...more

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