News & Analysis as of

Sanctions Financial Institutions

Baker Botts L.L.P.

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

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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

The Volkov Law Group

Interactive Brokers Settles with OFAC for $11.8 Million for Violations of Multiple Sanctions Programs

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced on July 15, 2025, that Interactive Brokers LLC (“IB”)—a globally active electronic brokerage firm headquartered in Greenwich,...more

Mayer Brown

FinCEN's First Strike: New Section 311 Powers Target Mexican Financial Institutions Under FEND Off Fentanyl Act

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In this episode, host Lauren Pryor and her colleagues discuss the recent actions by FinCEN, which designated three Mexican financial institutions as primary money laundering concerns under the expanded Section 311 authority,...more

A&O Shearman

EC adopts delegated regulation requiring a review of countries that may pose a threat to the EU financial system

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The European Commission (EC) has adopted a Delegated Regulation amending a Delegated Regulation it adopted on 10 June, to introduce a review clause requiring the EC to independently assess countries that may pose a threat to...more

Troutman Pepper Locke

NYDFS Warns of Heightened Risk From Global Conflicts: What Regulated Entities Must Do Now

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On June 23, the New York State Department of Financial Services (NYDFS) issued an industry letter to all regulated entities — banks, insurers, money transmitters, virtual currency companies, and others — cautioning that...more

DarrowEverett LLP

The DOJ’s New White-Collar Agenda: Implications for Businesses

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On May 12, 2025, the Department of Justice (the “DOJ”) released its criminal—and, more specifically, white collar crime enforcement—initiatives under the current administration. This is typical each time new leadership...more

Skadden, Arps, Slate, Meagher & Flom LLP

Understanding and Mitigating Legal and Compliance Risks Relating to Cartels and Transnational Criminal Organizations

On his first day in office, President Trump signed Executive Order 14157 calling for the designation of certain cartels and transnational criminal organizations (TCOs) as foreign terrorist organizations (FTOs) or specially...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Sanctions: A New Package, Guidance and Legal Clarifications

The future of international sanctions on Russia is not settled. Whilst the representatives of the US and Russia met in Saudi Arabia on 18 February 2025 to discuss possible avenues to peace in Ukraine, the foreign ministers of...more

Woods Rogers

Designating Cartels as Terrorists: Potential Impact on U.S. Businesses

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On his first day in office, President Trump signed an executive order (EO 14157) that sets in motion the designation of certain cartels and transnational crime gangs as terrorist organizations. The President declared a...more

Guidepost Solutions LLC

Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more

A&O Shearman

EU Final Guidance on Implementation of EU And National Sanctions

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The European Banking Authority has finalized two sets of guidelines setting common standards on the governance arrangements and the policies, procedures, and controls that financial institutions should have in place to be...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Sanctions Puzzle: Key Areas To Watch in 2025 and Beyond

The past weeks and months have brought about tremendous political change in the West, as we move toward a new U.S. administration, a new College of Commissioners in Brussels and a new Polish presidency of the Council of the...more

A&O Shearman

Sanction for scheme of arrangement refused by Hong Kong court: Key takeaways

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Notwithstanding that the requisite statutory majority was obtained in the relevant creditors’ scheme meeting, the Hong Kong Companies Court refused to sanction a scheme of arrangement propounded by a company that professed to...more

Davis Wright Tremaine LLP

Deadline Approaching for Filing 2024 OFAC Annual Report of Blocked Property

The annual September 30 deadline for submitting the Annual Report of Blocked Property (ARBP) to the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) is fast approaching. Under federal regulations, "all U.S....more

Ballard Spahr LLP

Federal Judge Sanctions Pittsburgh Law Firm for Writing ‘Imaginary’ Letters on Behalf of Clients in Debt Disputes

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A Pennsylvania federal judge has imposed sanctions and lambasted a law firm and its attorneys for having employees write falsified letters on behalf of clients involved in debt collection disputes....more

A&O Shearman

US imposes new sanctions and export controls against Russia

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On June 12, 2024, the U.S. Department of Treasury (Treasury), U.S. Department of State (State), and U.S. Department of Commerce (Commerce) announced another round of sanctions and export controls targeting Russia. In this...more

Sheppard Mullin Richter & Hampton LLP

OFAC Tightens Russia Sanctions; BIS Cracks Down on Diversion

On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including: 1. Expanding the scope of financial sanctions:...more

A&O Shearman

UK FCA Financial Crime Guide consultation: more obligations, or old news?

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As financial crime compliance pressures grow, the UK Financial Conduct Authority (FCA) continues to emphasise the significance of its Financial Crime Guide (FCG) as part of the overarching regulatory framework for financial...more

K2 Integrity

U.S. Congress Mandates Wide Range Of Sanctions In Ukraine, Israel, And Taiwan Aid Bill

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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

Conyers

Regulatory & Risk Advisory Review: Cayman Islands – January to March 2024

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Welcome to the first instalment of 2024 of our Cayman Islands Regulatory & Risk Advisory Review. As we cover in this issue, there have been a number of updates in the first quarter of the year. Perhaps most notably is the...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

A&O Shearman

Key Regulatory Topics: Weekly Update 8 - 14 Mar 2024

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There were some key publications this week in relation to financial crime, including a Commission request for the EBA to advise on standards and guidelines under the future AML/CFT framework in Europe and, in the UK, an HMT...more

Bass, Berry & Sims PLC

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

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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

A&O Shearman

Key Regulatory Topics: Weekly Update 23-29 Feb 2024

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Amongst the broad range of updates this week, at international level, the FSB published its thematic peer review on MMF Reforms and the BCBS published the outcomes of its meeting held on 28 and 29 February, including that it...more

Conyers

Regulatory & Risk Advisory Outlook 2024: Cayman Islands

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2023 was an active year for the Cayman Islands regulatory industry. While we have endeavoured to keep you updated throughout the year with our Regulatory & Risk Advisory Reviews, our team has highlighted below the key changes...more

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