FINCast Ep. 19 - The DPRK Sanctions Program
North Korean IT operatives are infiltrating U.S. and Western companies using stolen or fabricated identities, VPNs, and U.S.-based co-conspirators to gain unauthorized access to corporate systems. These insider threats pose...more
On November 26, the U.S. Fifth Circuit Court of Appeals overturned sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) against a decentralized cryptocurrency mixing service (a...more
You are reading the October 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. -...more
Throughout 2023 and early 2024, we continue to witness deepening geopolitical and economic divides globally. The U.S. and its allies (most significantly the EU and the G7), spurred on by Russia’s war in Ukraine, continue to...more
Background: On Friday November 29, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Sinbad.io (“Sinbad”), alleging that the virtual currency mixer serves as a key money-laundering...more
The U.S. authorities are increasingly taking actions against big-name crypto mixers for potential violations of sanctions regulations. On November 29, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control...more
On March 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13551, against a Slovakian national for attempting to facilitate arms deals between Russia...more
With the war in Ukraine raging on, the U.S. continued to escalate its sanctions response against Russia. The U.S. announced extensive trade and investment bans that prohibit U.S. persons from making any “new investment” in...more
On July 7, 2022, three federal agencies – the Federal Bureau of Investigation, the Cybersecurity and Infrastructure Security Agency, and the Department of the Treasury – issued a joint alert regarding Maui Ransomware, which...more
The world’s response to Russia’s invasion of Ukraine dominated the first quarter of 2022, as the US and its international partners coordinated efforts to impose unprecedented sanctions designed to isolate the Russian...more
In an increasingly integrated global economy, and as businesses shift to online sales and a broader client base, it is important to have a clear understanding of, among other things, the U.S. sanctions in place, and the...more
Proposed Rules on CFIUS Mandatory Declarations Released: No More NAICS Codes! On May 21, 2020, the Department of the Treasury released a proposed rule that would modify the requirements for Committee on Foreign Investment...more
Case Sheds Light on Latest Methods to Evade Detection: “Peeling” Chains - On March 2, the U.S. government sanctioned and indicted two Chinese nationals for helping North Korea launder nearly $100 million in stolen...more
Report on Supply Chain Compliance 2, no. 22 (November 21, 2019) - Women Mobilizing to End the War, Korea Peace Now, released a report on the impact sanctions have on the common citizens of the Democratic People’s Republic...more
Arrest of a Chinese National on Hacking Charges Illustrates How U.S. Tactics Are Changing to Meet the New Cyber Threat - In August, Yu Pingan, a Chinese national, was arrested on charges that he conspired to acquire and...more
The executive order expands the extraterritorial reach of existing North Korea sanctions by extending it to US persons’ dealings with non-US actors that do business with North Korea....more
Senate Again Delays Action on Remaining Appropriations Bill: The Senate has yet to schedule any mark-ups for next week for its remaining four appropriations bills (Clark Hill Insight). Senate Reaches Deal on Budget...more
Two days after North Korea’s successful long-range ballistic missile test, the U.S. District Court for the District of Columbia unsealed a memorandum opinion which granted the Department of Justice “damming” warrants to seize...more
As North Korea continues its provocative missile tests and nuclear activities, the United States appears poised to adopt secondary sanctions that would target Chinese and other firms conducting business with Pyongyang. Global...more
There have been a number of key developments in the European Union (“EU”) and United Kingdom (“UK”) sanctions regimes in relation to North Korea, Russia, Syria and other jurisdictions since our last update. North Korea -...more
In the wake of the nuclear test conducted by the Democratic People’s Republic of Korea (DPRK) on 9 September 2016, the Security Council, acting under Chapter VII of the UN Charter, has adopted new measures on 30 November...more
On November 30, 2016, the United Nations Security Council (UNSC) passed a unanimous resolution strengthening sanctions against North Korea. The Resolution comes in response to the conduct of the latest round of nuclear tests...more
Overview of US and EU Trade Sanctions - Following is a summary of the current US and EU sanctions that restrict trade with and/or investment in certain countries, “Specially Designated Nationals” (SDNs) and “Blocked...more
Making regular updates to policies and procedures related to international trade compliance has always been an important aspect of ensuring their effectiveness, and particularly in light of the myriad changes to various U.S....more
Below is a summary of developments since our previous update in January relating to European Union (“EU”) sanctions on Iran, Russia, Belarus, North Korea and other jurisdictions as well as highlights of recent changes with...more