Key Discovery Points: If You Dispose of Relevant Hard Drives You Will Face (Some) Consequences
eDiscovery Case Law Podcast: How Failing to Meet and Confer Effectively Can Lead to Sanctions
Episode 339: Four Sanctions Cases Everyone Should Know
Corruption, Crime and Compliance - “The New FCPA”: Sanctions and Export Control Enforcement and Compliance
Giving Compliance Advice
Corruption, Crime, & Compliance - Five Steps to Enhance Your Sanctions Compliance Program
Corruption, Crime and Compliance - Deep Dive Into Wells Fargo’s $30 Million OFAC Settlement
FINCast Ep. 36 – Regulators’ Roundtable to Forecast 2023
Guidepost in Motion EP25: State of Compliance with Alixandra Smith Part 2
FCPA Compliance Report - Matt Silverman on Potential Sanctions Against Russia
Argentina: A Look at the Case of Lázaro Báez - Laundering the Proceeds of Corruption and Tax Fraud
Nota Bene Podcast Episode 131: U.S. Sanctions Against Russia: Valid or Ineffective Economic Policy? with Fatema Merchant and Mario Torrico
Compliance into the Weeds - SAP Trade Sanctions Enforcement Action
What to Expect from the Biden Administration
A Look Ahead at the Biden Administration’s Regulatory and Enforcement Priorities
Compliance Perspectives: The German Corporate Sanctions Act
Episode 153 -- The Mighty Amazon Falls to OFAC Enforcement Sword
Navigating an Increasingly Complex Sanctions Landscape: New Exposures for Corporations and Shipping
Episode 120: Interview of NAVEX Global Third-Party Risk Officials: Chris Bailey and Stephen Gooding
U.S. policy reversal allows suits in U.S. courts and visa denials, for “trafficking” in confiscated property in Cuba
On March 11, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) aimed at disrupting drug trafficking and money laundering along the southwestern border. The...more
As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...more
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
Imposes maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist groups. Relevant Secretaries are required to impose and enforce sanctions,...more
As we head toward Valentine’s Day 2025, everywhere you look, love is all around. Washington, D.C., is no exception—the White House and government agencies seem to be proudly displaying their ardor for changing the country’s...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
Earlier this week, the U.S. Office of Foreign Assets Control (OFAC) and the UK Office of Financial Sanctions Implementation (OFSI) published a Memorandum of Understanding (MoU), which was previously signed on October 9, 2024,...more
On January 10, 2025, the US government issued the latest round of sanctions targeting Russia’s revenue sources used to fund its war in Ukraine....more
The US Office of Foreign Assets Control (OFAC) issued Syria General License 24 (GL 24) authorizing certain transactions with the new Syrian government and easing some transactions related to energy and personal remittances....more
In an effort to reduce Russian energy revenues being used to fund the war against Ukraine, on January 10, 2025, the United States Department of the Treasury's Office of Foreign Assets Control (OFAC), issued a “determination”...more
On January 10, 2025, in a final action to, among other things, deter Russian aggression on the international stage, the US Department of the Treasury enacted sweeping new sanctions on the Russian energy sector. Specifically,...more
On January 3, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions on a Chinese-based cybersecurity company, Integrity Technology Group, Inc. (“Integrity Tech”). These sanctions...more
On January 10, 2025, the United States announced (another) major sanctions package targeting Russia, potentially representing the Biden administration’s last and best effort to strengthen Ukraine’s negotiating position in...more
The US government signals careful optimism with a new general license authorizing some previously prohibited transactions, including many (but not all) transactions with Syrian governing institutions, for the next six months....more
On November 26, the U.S. Fifth Circuit Court of Appeals overturned sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) against a decentralized cryptocurrency mixing service (a...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 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
On April 17, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) released General License (GL) 44A, requiring the wind down of business transactions with Venezuela’s state-owned energy company Petróleos...more
Beginning in 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has increasingly focused its enforcement activity on entities operating in the virtual currency space, illustrating a trend that...more
On Wednesday, March 6, 2024, the Department of Commerce, Department of the Treasury and Department of Justice issued another Tri-seal Compliance Note, focusing this time on the obligations of foreign based persons complying...more
On February 23, 2024, the United States imposed its largest number of new sanctions and export control designations against Russia to date—targeting over 600 individuals and entities across a wide swath of the Russian economy...more
On October 18, 2023, the United States announced the suspension of certain sanctions related to Venezuela through the issuance of new and revised general licenses. The Office of Foreign Assets Control (OFAC) of the U.S....more
The Office of Foreign Assets Control (“OFAC”) is an arm of the U.S. Department of Treasury, tasked with administering and enforcing various economic and trade sanctions intended to further U.S. foreign policy and national...more
In a long-awaited decision involving the cryptocurrency “mixer” Tornado Cash, a U.S. district court on August 17, 2023, upheld the broad authority of the Department of the Treasury’s (Treasury’s) Office of Foreign Assets...more
Senate Adopts Outbound Investment NDAA Provision. On July 25, the Senate approved an amendment to the FY 2024 National Defense Authorization Act (NDAA) filed by Sens. John Cornyn (R-TX) and Bob Casey (D-PA) that would require...more