News & Analysis as of

U.S. Treasury Economic Sanctions Anti-Money Laundering

Patomak Global Partners

FinCEN Targets Three Mexican Financial Institutions for Fentanyl Trafficking

The Trump Administration has repeatedly signaled its prioritization of targeting traffickers of synthetic opioids, especially fentanyl. On January 20, 2025, President Trump signed an Executive Order “creating a process by...more

Foley & Lardner LLP

FinCEN Exercises New Authority Targeting Mexico-Based Financial Institutions to Counter Cartel-Linked Fentanyl Trade

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On June 25, 2025, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury designated three Mexico-based financial institutions as primary money laundering concerns under Section 311 of the USA...more

Morrison & Foerster LLP

FinCEN Targets Three Mexico-Based Financial Institutions with Sanctions Under New Authority to Address Money Laundering Associated...

On June 25, 2025, FinCEN issued its first orders under the 2024 FEND Off Fentanyl Act (FOFA), imposing special measures against three Mexican financial firms—CIBanco S.A., Institución de Banca Múltiple (CIBanco), Intercam...more

Holland & Knight LLP

FinCEN Advisory Highlights Iran Sanctions Evasion Red Flags

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The U.S. Department of the Treasury's (Treasury) Financial Crimes Enforcement Network (FinCEN), published the FinCEN Advisory on the Iranian Regime's Illicit Oil Smuggling Activities, Shadow Banking Networks, and Weapons...more

Lowenstein Sandler LLP

OFAC Imposes Largest-Ever Penalty on Nonbank Financial Institution for Egregious and Sustained Sanctions Violations—a $216M...

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a historic $215,988,868 civil monetary penalty against GVA Capital Ltd. (GVA), a venture-capital firm registered in the Cayman Islands...more

Secretariat

Guardians of Finance Integrity, How the NY Fed’s Oversight in Iraq and Libya Could Hold a Blueprint for Post-Conflict...

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The Federal Reserve Bank of New York (FRBNY) has cemented its role as a global financial watchdog, using its influence to safeguard the integrity of the U.S. dollar and the broader international financial system. Recent...more

Ballard Spahr LLP

Cracking Down on CJNG: FinCEN’s Alert and OFAC’s Strategic Sanctions on Oil Smuggling

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In a significant move to curb illegal activities at the U.S. Southwest border, the Financial Crimes Enforcement Network (FinCEN) issued an alert, on May 1, 2025, concerning oil smuggling from Mexico into the United States,...more

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

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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

Morgan Lewis

US Designation of Cartels as Terrorist Organizations Increases Risk of Doing Business in Mexico

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Recent US government actions indicate a possible increase in US financial crimes investigations and enforcement targeting drug cartels and transnational criminal organizations in Latin America....more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

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On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more

Jones Day

Mitigating Risk From the Designation of Cartels as FTOs and SDGTs

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The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more

K2 Integrity

Escalation Against Cartels: U.S. Designates International Cartels as Foreign Terrorist Organizations and Specially Designated...

K2 Integrity on

On 20 February 2025, the United States (U.S.) Department of State designated eight international cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The designation of...more

White & Case LLP

United States Designates Eight Cartels and Transnational Criminal Organizations

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Effective February 20, 2025, the United States Designated Eight Cartels and Transnational Criminal Organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs)....more

Latham & Watkins LLP

Trump Administration Targets Cartels With First Wave of Terrorism Designations

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The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....more

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

Arnall Golden Gregory LLP

OFAC and KoFIU Sanctions Compliance for Financial Technologies Companies

As financial technologies companies expand operations across borders, understanding the sanctions regimes of both the United States and South Korea becomes essential. The U.S. Treasury Department’s Office of Foreign Assets...more

Baker Botts L.L.P.

Compliance, Enforcement, and Litigation Risk Considerations from President Trump’s Executive Order on Designating New Foreign...

Baker Botts L.L.P. on

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.” The order directs the...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

Jones Day

Federal Agencies Highlight Benefits of Self-Disclosure, Emphasize Enforcement of Trade Violations in Tri-Seal Compliance Note

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In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

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On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

Torres Trade Law, PLLC

New Anti-Money Laundering Whistleblower Law Makes Economic Sanctions Violations Reportable

To more effectively counter transnational corruption and economic sanctions evasion, recent changes to the U.S. anti-money laundering (“AML”) whistleblower regime expand and reinforce whistleblower protections and rewards in...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Congress Fixes Major Hole In Treasury’s Nascent Whistleblower Program While Expanding Its Scope To Sanctions Evaders

Takeaways: •The Treasury Whistleblower Program now provides for guaranteed awards of 10% to 30% of the government recovery in covered actions- •The Treasury Whistleblower Program has been expanded to include not just tips...more

Orrick, Herrington & Sutcliffe LLP

Treasury official warns Turkish companies on engaging with Russian entities

On February 3, Under Secretary of the Treasury for Terrorism and Financial Intelligence, Brian E. Nelson, met with the Banks Association of Turkey to discuss international sanctions actions against Russia for its war against...more

K2 Integrity

U.S. Authorities Amplify Enforcement Efforts to Address Financial Crime Risks in the Digital Asset Industry

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The United States Department of the Treasury has continued to signal that it will focus policy, regulatory, and enforcement attention on the financial crime and sanctions risk in the crypto and digital asset ecosystem...more

Perkins Coie

Recent Developments in US Sanctions and Export Controls Targeting Russia

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Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more

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