FINCast Ep. 19 - The DPRK Sanctions Program
As an American living abroad, you may have experienced firsthand the challenges of finding a financial institution willing to work with you. Whether it’s for opening a bank account, investing in local markets, securing a...more
Every year, foreign lenders make thousands of loans to U.S. entities. The U.S. withholding tax on the related interest payments has been generally stable since 1984. The general rule is that interest paid under these loans...more
On 20 February 2025, the United States (U.S.) Department of State designated eight international cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The designation of...more
The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....more
On November 21, 2024, the Biden Administration announced sweeping new sanctions targeting numerous Russian banks, financial institutions and officials, including one of the largest remaining unblocked Russian banks,...more
On November 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took further action to restrict Russia’s access to the international financial system by designating Gazprombank Joint Stock...more
The Financial Action Task Force (FATF) has updated its ‘grey list’ of jurisdictions under increased monitoring, removing Senegal and adding Algeria, Angola, Côte d’Ivoire, and Lebanon. The intergovernmental organization made...more
In recent months, the United Kingdom’s sanctions regime has received noteworthy updates with implications for a range of entities operating both domestically and abroad. The changes are housed in an update to the Russia...more
A Gesture Providing Limited Solace to a Now-Defunct Bank - Six years ago, in early 2018, we blogged about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (“FinCEN’s”) designation of ABLV Bank, AS...more
On June 27, 2024, Switzerland and the United States executed the Agreement between Switzerland and the United States of America to Improve International Tax Compliance and to Implement FATCA (New IGA), which will take effect...more
January 29, 2024- The U.S. Department of the Treasury issued a finding and notice of proposed rulemaking (NPRM) that identifies an Iraqi bank that serves as a conduit for terrorist financing, as a foreign financial...more
On December 22, 2023, President Biden issued Executive Order (EO) 14114, imposing significant new economic sanctions against Russia to address the ongoing national security threat posed by the country’s invasion of Ukraine...more
On December 22, 2023, President Biden issued new Executive Order (“EO”) 14114, amending EO 14024 and EO 14068. The new EO grants the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) authority to...more
On December 22, 2023, President Biden issued a new Russia-related Executive Order (“EO”) targeting foreign financial institutions (“FFIs”) that support Russia’s military-industrial base. The new EO allows the U.S. government...more
On December 22, 2023, President Biden signed Executive Order 14114, titled “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities” (EO 14114), with a focus on holding foreign financial...more
Over a year has now passed since Russia invaded Ukraine, and the U.S., the EU and its member states, the U.K., and many others—including Japan, Australia, New Zealand, Taiwan and Canada—continue to exert pressure on Russia...more
Le 17 février 2023, le gouvernement fédéral a publié un projet de règlements modificatifs (les « Règlements modificatifs ») modifiant certains règlements (les « Règlements ») pris en vertu de la Loi sur le recyclage des...more
On February 17, 2023, the federal government released draft amending regulations (Amending Regulations) to the regulations (Regulations) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and...more
Bajo el concepto de “FATCA recíproca”, las instituciones financieras y los corredores deben comenzar a prepararse para asumir mayores y más amplias responsabilidades de reportaje. Como partes interesadas de FATCA, las...more
The Financial Crimes Enforcement Network (“FinCEN”) has been busy during the last few weeks – and presumably will remain busy for the rest of 2021, as it attempts to satisfy numerous mandates imposed by the Anti-Money...more
OECD Guide Offers Financial Institutions Advice on Hiring External Service Organizations to Handle Compliance - While financial institutions (FIs) have final responsibility for compliance with the Foreign Account Tax...more
President Trump signs law authorizing sanctions on individuals and financial institutions and ends U.S. preferential treatment for Hong Kong. The Hong Kong Autonomy Act authorizes sanctions on foreign financial...more
On October 25, 2019, FinCEN issued a final rule imposing the Fifth Special Measure against the Islamic Republic of Iran as a “jurisdiction of primary money laundering concern” (“Final Rule”) under Section 311 of the USA...more
Leaders of FinCEN, CFTC and SEC Attempt an Intricate Dance of Competing Oversight of Virtual Currency - On October 11, the leaders of the Financial Crimes Enforcement Network (“FinCEN”), the Commodity Futures Trading...more
In the recent case of Lamesa Investments Ltd v Cynergy Bank Ltd [2019] EWHC 1877 (Comm), the High Court upheld the bank’s attempt to avoid a common banking dilemma: the ‘double jeopardy’ of being contractually liable to make...more