All Things Investigations: Episode 30 - The Convergence of ABC, AML and Export Controls with Mike Huneke and Jan Dunin-Wasowicz
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has significantly increased its focus on sanctions compliance for “financial gatekeepers,” including financial institutions and other firms...more
There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more
The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more
New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more
On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more
OFAC continues its enforcement push. At the same time, OFAC is managing a complex, global set of sanctions against Russia. DOJ has promised to increase prosecution of global banks for sanctions violations....more
On May 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a roughly $7.6 million settlement with a Massachusetts-based online trading and settlement platform to resolve potential civil...more
With the ever-increasing use of sanctions as a foreign policy tool (or weapon), sanctions compliance has taken on greater importance than ever. Moreover, as countries increase extraterritorial applications of their sanctions,...more
On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...more
With the Russian-Ukraine war’s ever-expanding sanctions landscape, the supply chain is even more complex than it already was, and enforcement risk is even higher given the broader array of U.S. federal and international...more
“Know your customer” is a bed rock principle of anti-money laundering and sanctions compliance programs, but it’s not always easy, particularly as more sophisticated and aggressive players have taken the field in recent...more
On Oct. 15, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) published sanctions compliance guidance for the virtual currency industry. OFAC acknowledged that virtual currencies are playing an...more
On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more
How can a compliance professional navigate an increasingly complex sanctions landscape around a best practices sanctions compliance program and what happens if there is a compliance failure? I recently visited with Adam Frey,...more
Apollo Settles Alleged Sanctions Violations: Aircraft Lessors Pay Attention - The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has broad delegated authority to administer and enforce the...more
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has broad delegated authority to administer and enforce the sanctions laws and related sanctions programs of the United States. As a key...more
I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more
Last week, British Arab Commercial Bank (BACB), located in the United Kingdom, agreed to settle an OFAC enforcement action for $4 million. ...more
Virtual currencies like Bitcoin and Ethereum have spawned many types of businesses that need banking services. Many banks "de-risk" -- do not provide banking services -- to these businesses. Many virtual currency...more
You are the chief legal officer of a U.S. company. Your CEO walks into your office and announces that your company is about to conclude its first international sale. In addition, the company has just appointed distributors in...more