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]
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
On August 19, the U.S. Treasury Department officially withdrew a contentious proposal from 2020 that aimed to impose know-your-customer requirements on non-custodial cryptocurrency wallets....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
Teradyne, a Massachusetts-based supplier of semiconductor testing equipment, has reportedly pulled $1 billion of manufacturing equipment out of China in 2023 following export controls on advanced computing materials and...more
Although the Corporate Transparency Act (CTA”) was adopted in 2021, implementation has been delayed while the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) established regulations. The deadline,...more
企業透明性法（以下「法」）は2021年に採択されたが、財務省の金融犯罪取締ネットワーク（以下「FinCEN」）が規制を設ける間、施行が遅れていました。しかし、その遵守期限は間近に迫っています。2024年1月1日以降に設立される報告対象会社は、設立後30日以内に報告書を提出する必要があります。2023年末時点ですでに存在する報告対象会社は、2024年末までに最初の報告を行う必要があります。...more
Although the Corporate Transparency Act (the “Act”) was adopted in 2021, implementation has been delayed while the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) established regulations. The...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
Back in July, we took a look at the enforcement actions for the first half of 2021 issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Today’s post – the second half of our OFAC 2021 Year...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
Auto dealerships and lenders are likely familiar with “know your customer” requirements, which typically involve obtaining identification information from customers and verifying that information. Most lenders are also...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
The Corporate Transparency Act (CTA), part of the 2021 National Defense Authorization Act enacted into law on January 1, 2021, will impose new beneficial ownership reporting requirements on many companies. The stated purposes...more
Effective as of January 1, 2021, Congress enacted - over President Trump's veto - the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (the "NDAA"). As with any U.S. defense bill, the NDAA...more
Treasury Secretary Steven Mnuchin remarked before a hearing of the Senate Finance Committee three weeks ago that “significant new requirements at FinCEN” for cryptocurrencies would be introduced quickly, in response to...more
Notwithstanding Lloyd’s assurances that the rumors of his demise are premature, Goldman has cleared the path forward for David Solomon (aka, one of its current co-Presidents, aka, DJ D-Sol) to assume the CEO position when Mr....more
On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) that would impose certain anti-money laundering (“AML”) requirements on...more