Episode 324 -- Third-Party Risks and Sanctions Compliance
FINCast Ep. 39 – State of Russia Sanctions Two Years After the Invasion
Understanding the Additional Risks When Making a Ransomware Payment
Looking The Other Way: Recent Cases Of AML And Sanctions Failings In Scandinavia
Episode 118 -- Update on OFAC Enforcement and Lessons Learned
On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) reached a settlement with Key Holding, LLC (Key Holding) concerning its non-U.S. subsidiary’s violations of the Cuban Assets...more
OFAC means what it says — in more ways than one. In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations....more
Key Points: - Long-arm of U.S. sanctions jurisdiction reaches conduct by European company. - Violation involved shipment to Iran from Australia, a close U.S. ally. On December 3, the Treasury Department’s Office of...more
European Union member states have until 20 May 2025 to transpose into their national legislation EU Directive (EU) 2024/1226 (the Directive), which establishes minimum rules on the definition of criminal offences and...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
On 24 April 2024, the EU adopted a new directive (Directive (EU) 2024/1226 of the European Parliament and of the Council) which establishes EU-wide rules for defining criminal offences and penalties related to the violation...more
On 24 April 2024, President Biden signed into law H.R. 815, “Making Emergency Supplemental Appropriations for the Fiscal Year Ending September 30, 2024, and for Other Purposes” (the Act). The long-awaited piece of legislation...more
Effective April 24, the statute of limitations (“SoL”) under the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) has been extended from five to ten years. It would have been...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
The Court of Appeal found a confirming bank to be in breach of contract by declining to make payment under a confirmation to a letter of credit on the basis that a sanctions prohibition applied....more
Key Points - - The US Department of Justice reported that it obtained a warrant for the seizure of a Boeing 737-7EM aircraft for the alleged violation of US export controls on Russia (rather than because of ownership of...more
1. Expanded Export Controls on Certain Biological Equipment Software Are Coming- As part of the Bureau of Industry and Security’s emerging and foundational technology control effort, new export controls are forthcoming...more
On February 18, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a half-million dollar settlement with BitPay, Inc. (“BitPay”), a U.S. company that processes digital currency...more
On July 8, the U.S. Department of the Treasury announced a settlement with Amazon.com, Inc., related to the company's potential civil liability for apparent violations of multiple sanctions programs resulting from...more
IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more
ANTICORRUPTION DEVELOPMENTS - DOJ Unseals Indictment of Two More Individuals Connected With PDVSA Corruption Scheme - On February 26, 2019, the U.S. Department of Justice (DOJ) announced the unsealing of an indictment...more
ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more
Most people outside of the law do not realize how valuable evidence is in resolving courtroom disputes. There are a variety of rules around what is and what is not a trustworthy fact, but a participant in a case is typically...more