News & Analysis as of

Office of Foreign Assets Control (OFAC) Beneficial Owner

Baker Botts L.L.P.

Beyond the Fine: What Financial Gatekeepers Must Learn from Interactive Brokers’ OFAC Settlement

Baker Botts L.L.P. on

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

King & Spalding

Recent OFAC and DOJ Activity Signals Potential New Era of Control-Based Sanctions Enforcement

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U.S. sanctions enforcement is evolving to adopt a “control” analysis similar to the analysis employed by the European Union and United Kingdom based on a recent major enforcement action by the U.S. Department of the...more

Lowenstein Sandler LLP

OFAC Imposes Largest-Ever Penalty on Nonbank Financial Institution for Egregious and Sustained Sanctions Violations—a $216M...

Lowenstein Sandler LLP on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a historic $215,988,868 civil monetary penalty against GVA Capital Ltd. (GVA), a venture-capital firm registered in the Cayman Islands...more

Morgan Lewis

OFAC Action Shows Risk of Not Recognizing That ‘Property Interests’ Include ‘Any Interest Whatsoever’

Morgan Lewis on

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) fined GVA Capital Ltd. $215 million, primarily for violating the Ukraine/Russia-related sanctions regulations, when GVA mistakenly concluded that it...more

Paul Hastings LLP

Public Company Watch: March 2024

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In the March edition of our Public Company Watch, we cover key issues impacting public companies, including the new climate disclosure rules, SEC scrutiny on beneficial ownership filings, West Palm Beach Firefighters’ Pension...more

Foodman CPAs & Advisors

BOI Acceso Y Salvaguardas

El 2/20/23, FinCEN publicó la Guía de Cumplimiento para Pequeñas Entidades para los requisitos de Acceso y Salvaguardas de la información sobre los Beneficiarios Finales. La Guía de BOI Acceso y Salvaguardas (de seis páginas...more

Foodman CPAs & Advisors

BOI Access & Safeguards

On 2/20/23, FinCEN published the Small Entity Compliance Guide for Beneficial Ownership Information Access and Safeguards Requirements. The (six-pages and four sections) BOI Access & Safeguards Guide provides an overview...more

American Conference Institute (ACI)

Sanctions Compliance Measures to Mitigate Russia Trade Sanctions Evasion Tactics

The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more

Paul Hastings LLP

Public Company Watch: January 2024

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In the January Public Company Watch, we cover key issues impacting public companies, including navigating the 2023 20-F season, updated SEC guidance related to confidential treatment applications, the Delaware Court of...more

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

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As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - December 2023

Lowenstein Sandler LLP on

TRADE TIP OF THE MONTH: New Companies Have More Time To Report Ownership- The Treasury Department’s Financial Crimes Enforcement Network issued a final rule in late November to delay the deadline for newly created...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - November 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Ballard Spahr LLP

SEC Exam Priorities Target AML

Ballard Spahr LLP on

Priorities Echo Prior Alerts and Enforcement Actions - The SEC’s Division of Examinations (the “Division”) released on October 16 a report on its “Examination Priorities” (the “Report”) for fiscal year 2024. This release...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - October 2023

Lowenstein Sandler LLP on

1. Seagate Technology Gets Largest-Ever BIS Penalty for Sales to Huawei- Seagate Technology LLC recently incurred a $300 million civil penalty from U.S. Department of Commerce’s Bureau of Industry and Security (BIS) due to...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

Ballard Spahr LLP on

The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

Cadwalader, Wickersham & Taft LLP

Sanctions Savvy - May 2022 | Issue No. 175 - LP Sanctions Risk in Fund Finance: Issues for Lenders to Consider

We have been closely monitoring the sanctions landscape over the last few months. Back in March, we covered the sanctions levied by the United States and other jurisdictions in response to Russia’s invasion of Ukraine. The...more

Holland & Knight LLP

Navigating Russian Sanctions in Corporate Jet Transactions

Holland & Knight LLP on

The U.S., European Union (EU), United Kingdom (U.K.) and many other countries have imposed similar but not necessarily identical sanctions on Russia. In corporate jet transactions, the sanctions laws of several jurisdictions...more

Eversheds Sutherland (US) LLP

Financial Crime Horizon Scanner: 2022 - Q1 (US)

Our quarterly Financial Crime Horizon Scanner for the US summarizes key financial crime related legal and regulatory changes expected over the next 2 years and provides electronic links to key resources. We hope that you...more

Perkins Coie

Blockchain Week in Review - April 2021 #3

Perkins Coie on

The Regulation Process for FinCEN’s New Beneficial Ownership Reporting Requirement Launches - The Financial Crimes Enforcement Network (FinCEN) issued an Advanced Notice of Proposed Rulemaking (ANPRM) on Thursday to solicit...more

Cohen & Gresser LLP

Congress Votes on Federal Oversight for Antiquities and Heightened Scrutiny of the Art Market

Cohen & Gresser LLP on

On January 1, 2021, the Senate and the House of Representatives voted to override President Trump’s veto of the National Defense Authorization Act (NDAA) of 2021. The NDAA introduces legislation that allows federal oversight...more

The Volkov Law Group

Practical Risk-Based Ranking Strategies to Beneficial Ownership Issues (Part III of IV)

The Volkov Law Group on

At the outset, if you have a headache after reading my first two posts on the beneficial ownership issue, I apologize.  The issues twist and turn depending on whether the situation involves OFAC sanctions or corruption risks,...more

The Volkov Law Group

Five Common Weaknesses in OFAC Sanctions Compliance Programs

The Volkov Law Group on

As companies elevate their “game” in sanctions compliance, it is important that compliance officers critically examine the strengths and weaknesses of their compliance programs.  Many companies already have a screening...more

The Volkov Law Group

Making the Case for Requiring Beneficial Ownership Information

The Volkov Law Group on

In this era of aggressive enforcement, global companies have to integrate beneficial ownership requirements when conducting due diligence of business associates and when engaging customers....more

Foodman CPAs & Advisors

FATCA, FCPA, AML and OFAC allow the US to regulate the world. But what does it really mean?

In the current environment of increased regulation, transparency, reporting and heightened compliance standards, the US and its Government Agencies have an arsenal of tools with extraterritorial application. ...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Chinese

LATAM Airlines Agrees to Pay $22 Million to Settle FCPA Cases - Last month, LATAM Airlines (“LATAM”), based in Santiago, Chile, agreed to pay $22 million to settle parallel civil and criminal proceedings involving...more

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