News & Analysis as of

Office of Foreign Assets Control (OFAC) Compliance Know Your Customers

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

Guidepost Solutions LLC

Money Laundering, Terrorist Financing, and Investment Advisors – Yes, Financial Crime is Borderless and Legal Entity-Agnostic

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

BakerHostetler

Key Export Control Developments During the First Quarter of 2024

BakerHostetler on

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

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

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

The Volkov Law Group

OFAC Reaches Settlement with Cryptocurrency Company CoinList for Violations of Ukraine/Russia Sanctions

The Volkov Law Group on

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

The Volkov Law Group

Swedbank Latvia Settles with OFAC for $3.43 Million for Crimea Sanctions Violations

The Volkov Law Group on

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

Orrick, Herrington & Sutcliffe LLP

OFAC reaches $7.6 million settlement with online digital-asset trading platform

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

Morgan Lewis

Conducting Effective Sanctions and Anti-Money Laundering Diligence on Non-Latin-Based Entities

Morgan Lewis on

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

BakerHostetler

US Crypto Exchange Consents to $100M DFS Settlement for AML Compliance Failures

BakerHostetler on

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

Guidepost Solutions LLC

Sanctions and The Supply Chain: Basic Steps to Protect Yourself

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

Bracewell LLP

KYC in a Digital World, How New Sanctions and AML Expectations Have Upped the Stakes and What you Need to Do About it

Bracewell LLP on

“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

Herbert Smith Freehills Kramer

OFAC Issues Sanctions Compliance Guidance for Virtual Currency Industry

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

WilmerHale

OFAC Imposes New Sanctions to Thwart Ransomware

WilmerHale on

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

Thomas Fox - Compliance Evangelist

Navigating an Increasingly Complex Sanctions Landscape, Part 2-Compliance Programs and Remediation

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

Vedder Price

Global Transportation Finance Newsletter - December 2019

Vedder Price on

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

Vedder Price

Apollo Settles Alleged Sanctions Violations: Aircraft Lessors Pay Attention

Vedder Price on

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

Thomas Fox - Compliance Evangelist

The OFAC Compliance Framework: Element 2 – Risk Assessment

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

The Volkov Law Group

UK Bank Agrees to Pay $4 Million to Settle OFAC Sudanese Sanctions Violations

The Volkov Law Group on

Last week, British Arab Commercial Bank (BACB), located in the United Kingdom, agreed to settle an OFAC enforcement action for $4 million. ...more

Ward and Smith, P.A.

Should You Bank a Virtual Currency Business?

Ward and Smith, P.A. on

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

Williams Mullen

Export Control Laws for the General Counsel

Williams Mullen on

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

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