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 May 1, 2025, the Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) regarding the Huione Group, a foreign financial institution located in Cambodia. This proposal, enacted under...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
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 6, 2024, the Regulation of Payment Services and Payment Initiation Law came into effect. Relevant entities may now submit license applications for providing payment and payment initiation services....more
The recently announced sanctions by the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) sent shockwaves through the Russian financial system, forcing the Moscow Exchange (MOEX) to halt trading of U.S....more
The full text of the new Credit Institution Law No. 32/2024/QH15 (the "New Law") adopted by the National Assembly on 18 January 2024 has now been released. The New Law governs Vietnamese credit institutions and foreign bank...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 22 December 2023, the Biden administration issued Executive Order 14114, “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” (EO 14114), thereby amending EOs 14024 and 14068. The new EO...more
The Australian Securities and Investments Commission (ASIC) released on 10 March 2020 its finalised Regulatory Guide 176 for Foreign Financial Services Providers (FFSPs). There are some differences in the final RG 176...more
NYDFS Action Highlights the Need for Good Monitoring – and Good Consultants - In part one of this two-part post, we provided some practical tips for financial institutions to increase the chances that their Anti-Money...more
El 11 de Noviembre del 2018, el Departamento de Justicia de los EE. UU. (“DOJ”) informó que el banquero Adrian Baron, el ex Director de Negocios y ex Director Ejecutivo de Loyal Bank Ltd, un banco “off-shore” con oficinas en...more
On September 11, 2018, the US Department of Justice (DOJ) reported that banker Adrian Baron, the former Chief Business Officer and former Chief Executive Officer of Loyal Bank Ltd, an off-shore bank with offices in Budapest,...more
The Situation: Many foreign financial services providers ("FFSPs") currently rely on one of two types of relief from broadly defined provisions of the Corporations Act 2001 that would otherwise require them to obtain and hold...more
SEC/CORPORATE - On November 1, the Division of Corporation Finance of the Securities and Exchange Commission (Division) published Staff Legal Bulletin No. 14I (SLB 14I), which provides new, issuer-friendly guidance on...more
Automatic exchange of information (AEOI) regimes, primarily aimed at curbing tax avoidance through the use of foreign accounts and investment platforms, have recently become a global trend, starting with the adoption of the...more