News & Analysis as of

U.S. Treasury Department of Justice (DOJ) International Emergency Economic Powers Act (IEEPA)

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

DLA Piper on

Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

Ballard Spahr LLP

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

Ballard Spahr LLP on

In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado...more

Sheppard Mullin Richter & Hampton LLP

SoL Long to Short Limits: The Sequel — A Decade of Recordkeeping and Enforcement

On July 22, 2024, the Department of Treasury, Office of Foreign Assets Control (OFAC) announced a significant planned extension to its recordkeeping requirements, which will increase the retention period from five to ten...more

Morrison & Foerster LLP

War Aid and Sanctions: National Security Act Includes Significant New Sanctions Authorities

On April 24, 2024, President Biden signed into law a long-debated $98 billion foreign aid and national security legislative package (the “Act”) providing funds for Israel, Taiwan, and Ukraine, and authorizing new sanctions...more

Mayer Brown

US Agencies’ Tri-Seal Compliance Note Emphasizes Extraterritorial Reach of Sanctions and Export Control Obligations

Mayer Brown on

On March 6, 2024, the US Departments of Commerce (“Commerce”), Treasury (“Treasury”), and Justice (“DOJ”) released their latest Tri-Seal Compliance Note (“Note”), which focuses on the “Obligations of foreign-based persons to...more

Cadwalader, Wickersham & Taft LLP

U.S. Deploys Pincer Maneuver on Perceived Crypto Abuses

Crypto’s two calling cards, decentralization and anonymity, can lead to abuses, such as money laundering and tax evasion. The U.S. Treasury has long combatted crypto money laundering...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – October 2023 Update

Bass, Berry & Sims PLC on

October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading...more

Ballard Spahr LLP

All Roads Lead to Roman: Alleged Tornado Cash Co-Founders Roman Storm Arrested and Roman Semenov Sanctioned, Days After Treasury...

Ballard Spahr LLP on

Complex Civil and Criminal Cases Converge - On August 17, 2023, Judge Robert Pitman of the federal district court for the Western District of Texas issued an Order granting summary judgment for the U.S. Treasury Department...more

Snell & Wilmer

Voluntary Self-Disclosures: Update on Federal Agencies’ Efforts to Incentivize Self-Reporting Violations

Snell & Wilmer on

United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more

K2 Integrity

The North Korean Crypto Threat

K2 Integrity on

Executive Summary - The North Korean threat to the crypto ecosystem is the highest form of immediate risk to the crypto-economy driven by a regime that seeks to profit from its misuse to reinforce its regime and fuel all its...more

Ballard Spahr LLP

Turkey’s Majority State-Owned Halkbank Is Not Immune from U.S. Prosecution in Iran Sanctions and Money Laundering Case

Ballard Spahr LLP on

Court Rejects Halkbank’s Claim That the Foreign Sovereign Immunities Act Shields the Bank From Prosecution - A motion to dismiss an indictment accusing Turkey’s majority state-owned Halkbank of money laundering, bank...more

ArentFox Schiff

Pentagon Identifies 20 ‘Communist Chinese Military Companies’

ArentFox Schiff on

As the US technology competition with China continues to intensify, the Trump Administration has taken another step to tighten the screws on China. In late June, the US Department of Defense (DoD) made public a list of 20...more

King & Spalding

Virtual Currency as a Threat to National Security?

King & Spalding on

In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd. a...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd. a...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - January 2018

ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd....more

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