News & Analysis as of

International Emergency Economic Powers Act (IEEPA) Office of Foreign Assets Control (OFAC) Financial Institutions

Foley & Lardner LLP

FinCEN Exercises New Authority Targeting Mexico-Based Financial Institutions to Counter Cartel-Linked Fentanyl Trade

Foley & Lardner LLP on

On June 25, 2025, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury designated three Mexico-based financial institutions as primary money laundering concerns under Section 311 of the USA...more

Bracewell LLP

Trump Administration Efforts to Eliminate Cartels Pose Heightened Risk for Financial Institutions

Bracewell LLP on

As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

Troutman Pepper Locke on

On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more

K2 Integrity

Escalation Against Cartels: U.S. Designates International Cartels as Foreign Terrorist Organizations and Specially Designated...

K2 Integrity on

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

Latham & Watkins LLP

Trump Administration Targets Cartels With First Wave of Terrorism Designations

Latham & Watkins LLP on

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

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

DLA Piper on

Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

Ballard Spahr LLP

Steel Company President with Ties to Russian Oligarch Pleads Guilty to Money Laundering Conspiracy Involving Alleged Sanctions...

Ballard Spahr LLP on

Earlier this month, John Can Unsalan, the president of a steel-making company with ties to Russian oligarchs, pled guilty to one count of conspiracy to commit money laundering, based on financial transactions committed with...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2023

Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more

Mintz

DOJ issues charges in first criminal cryptocurrency sanctions case

Mintz on

Last Friday, a federal Magistrate Judge in Washington, D.C. wrote an opinion, in a still sealed case, explaining why he approved a DOJ criminal complaint against an American citizen accused of transmitting more than $10...more

Morgan Lewis

Update: US Sanctions on Russia Have Extraterritorial Implications

Morgan Lewis on

In connection with recent Russia-related sanctions issued by the US government, organizations face a variety of issues when navigating the questions of who and what transactions may be subject to the reach of these sanctions....more

Neal, Gerber & Eisenberg LLP

Potential Sanctions Risks for Facilitating Ransomware Payments

On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory to highlight the sanctions risks associated with ransomware payments related to malicious cyber-enabled...more

Ballard Spahr LLP

FinCEN and OFAC Advisories Aim to Increase Cybersecurity Awareness and Thwart Ransomware Attacks in the Financial Sector

Ballard Spahr LLP on

October is National Cybersecurity Awareness Month, and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and Office of Foreign Assets Control (“OFAC”) kicked off the month by issuing two...more

Bilzin Sumberg

OFAC Issues Regulatory Advisory Warning Against Facilitating Ransomware Payments

Bilzin Sumberg on

On October 1, 2020, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an “Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” The Advisory, which does not carry the...more

Williams Mullen

U.S. Sanctions Laws: Dangers Ahead For Foreign Companies (Part I)

Williams Mullen on

International companies are signaling growing concern about the U.S. sanctions laws. These laws impose restrictions on entering business transactions with certain targeted countries, companies and even individual persons...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd. a...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd. a...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - January 2018

ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd....more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - October 2017

ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more

Akerman LLP

Recent Trends in DOJ Investigations Against Major Financial Institutions Involving U.S. Economic Sanctions

Akerman LLP on

With the imposition of billion-dollar fines against large financial institutions, the U.S. Department of Justice ("DOJ") is focusing on banks for not only failing to comply with federal laws, but also for willfully violating...more

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