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
On his first day in office, President Donald Trump signed an executive order that initiates the process of designating certain drug cartels as foreign terrorist organizations. The executive order is primarily focused on...more
The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...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
Silicon Valley Bank, Santa Clara, California, was closed on March 10 by the California Department of Financial Protection and Innovation (CDFPI). On March 12, the New York State Department of Financial Services (NYSDFS)...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
With Russia’s invasion of Ukraine last week, we saw a swift response by the U.S. beginning with President Biden’s Executive Order 14024 (“The EO”) and followed quickly by the Office of Foreign Assets Control’s (“OFAC”) severe...more
The Bank Secrecy Act (BSA) and parts of the U.S. Patriot Act’s Office of Foreign Asset Control (OFAC) requirements have seemingly similar goals: to prevent money laundering and the funding of terrorist activities. Yet a...more
Cryptocurrency, and its most-noted asset Bitcoin, has been breaking into the mainstream press. While most lawyers have heard terms like “blockchain” and probably even know a few people who have been deeply interested in the...more
On 6 November we held a breakfast seminar focusing on the most important sanctions issues affecting the City and how to manage compliance with different financial sanctions regimes effectively. ...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
The opening of Cuba to greater commercial and financial activity offers many possibilities for U.S. financial institutions but, with those possibilities, comes a responsibility to meet the complex compliance challenges that...more