News & Analysis as of

Office of Foreign Assets Control (OFAC) Financial Institutions Corporate Counsel

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

Troutman Pepper Locke

Major OFAC Penalty for US Venture Capital Fund – Key Takeaways

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On June 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a civil penalty of approximately $216 million on GVA Capital Ltd., a venture capital firm based in San Francisco, for...more

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

Troutman Pepper Locke on

On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

Bass, Berry & Sims PLC

Swiss Finance Company to Pay Almost $4 Million for Sanctions Violations

Bass, Berry & Sims PLC on

On March 14, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced that EFG International AG (EFG), a Switzerland-based bank, had agreed to pay roughly $3.74 million to settle allegations that it had...more

Porter Hedges LLP

Update on Russian-Related Sanctions and Export Controls

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As the Russian invasion of Ukraine continues, the executive branch is mounting what the U.S. Department of Treasury (“Treasury”) calls a “historically unprecedented campaign of sanctions and export controls” aimed at...more

Sheppard Mullin Richter & Hampton LLP

The EU – U.S. Sanctions Dilemma: The Advocate General of the European Court of Justice Weighs in

In May 2018 the United States announced the reinstitution of sanctions against Iran that had previously been lifted pursuant to the Joint Comprehensive Plan Action (“JCPOA”). The U.S. sanctions on Iran that were revived...more

American Conference Institute (ACI)

[Virtual Event] Asia Pacific Conference on Economic Sanctions Compliance and Enforcement - May 27th - 28th, 9:00 am - 1:15 pm SGT

ACI’s Asia-Pacific Advanced Conference on Economic Sanctions Compliance and Enforcement is the largest sanctions gathering in Asia for financial institutions and global exporters. This unique conference features senior...more

Akin Gump Strauss Hauer & Feld LLP

DOJ Provides Additional Incentives for Voluntary Self-Disclosures of Criminal Export Controls and Sanctions Violations

• On December 13, 2019, the Department of Justice (DOJ) revised and re-issued its “Export Controls and Sanctions Policy for Business Organizations” (the “Revised Policy”) to “provide greater clarity for companies faced with a...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Adds Iranian Bitcoin Exchangers’ Names and Wallet Addresses to SDN List, Ushers in “New Approach” to Sanctions Enforcement

• On November 28, 2018, OFAC designated two Iran-based individuals who helped exchange cryptocurrency (bitcoin) into fiat currency on behalf of alleged ransomware perpetrators who targeted U.S. businesses and municipal...more

Holland & Knight LLP

Panama Papers Fallout: A Push for Transparency and Regulatory Reform - Sanctions Also Levied Against Several Panama-Based...

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In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

Davis Wright Tremaine LLP

Violation of OFAC Reporting Requirements: “No Harm, No Foul”? No Way!

A recent enforcement action by the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) against MasterCard International Incorporated (“MasterCard”) stands as a reminder of the importance of strictly...more

Akerman LLP

Recent Trends in DOJ Investigations Against Major Financial Institutions Involving U.S. Economic Sanctions

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With the imposition of billion-dollar fines against large financial institutions, the U.S. Department of Justice ("DOJ") is focusing on banks for not only failing to comply with federal laws, but also for willfully violating...more

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