The Department of Justice’s (“DOJ”) Data Security Program (“the Program”, 28 C.F.R. Part 202) went into effect on April 8 with a 90-day period of limited enforcement. With DOJ now expecting full compliance, with additional...more
The recent termination of the parole program for Cubans, Haitians, Nicaraguans and Venezuelans (CHNV) by the Department of Homeland Security (DHS), and subsequent termination of work authorization for CHNV parolees, has...more
icraAs artificial intelligence reshapes financial compliance practices, regulators across Latin America and globally are increasing their scrutiny of AI-based AML tools. This article explores the growing audit gap, and what...more
President Trump’s “America First Trade Policy” is creating new sanctions compliance risk for financial services institutions and companies in an area that historically has not received as much enforcement attention: drug...more
With unprecedented change and intensifying enforcement, now is the time to ensure your team is prepared for what’s ahead. Ensure that you don’t miss out on critical U.S. and international economic sanctions updates and the...more
On March 4, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 41A, “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint...more
Announced in a Federal Register notice published Feb. 5, 2025, DHS Secretary Kristi Noem decided not to extend the 2023 Venezuela Temporary Protected Status (TPS) designation. That designation will expire April 7, 2025....more
In this weekly update, we summarise the most notable updates in the UK sanctions world....more
On Friday, December 27, 2024, the Justice Department issued a final rule to address “urgent national security risks posed by access to U.S. sensitive personal and government-related data from countries of concern and covered...more
Telefónica Venezolana C.A. (“Telefónica Venezolana”), the Venezuela-based subsidiary of Telefónica S.A. (Telefónica), the Spanish telecommunications company entered into a deferred prosecution agreement (“DPA”) and agreed to...more
Key Points - On April 17, 2024, based on a determination by the U.S. government that Nicolás Maduro and his representatives “have not fully met the commitments made” with respect to upcoming Venezuelan elections, the U.S....more
During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more
Easy come, easy go. On January 29, 2024, OFAC published General License 43A under the Venezuela Sanctions Regulations, which partially rolled back a piece of the sanctions relief it provided to the country only a few months...more
On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) eased certain sanctions on the oil and gas sector, as well as the gold sector, in Venezuela, following the announcement of a...more
Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de EE.UU. promulgó una serie de licencias generales al gobierno de Venezuela para brindarle un alivio al país de las sanciones económicas. La OFAC promulgó...more
As we discussed previously, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently provided Venezuela with much needed sanctions relief. Specifically, OFAC issued General License 44 (among...more
El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados Unidos tomó varias medidas para proporcionar un alivio (limitado) de sus sanciones económicas en...more
On October 18, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) took several steps to provide Venezuela with some limited relief from its sanctions. The relief includes General Licenses...more
Uphold is a California-based money service business. Uphold agreed to pay OFAC $72,230 to resolve multiple sanctions program violations....more
On March 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $72,230 settlement with a global digital trading platform to resolve allegations that it processed transactions for customers who...more
The American Conference Institute is hosting their 17th Annual Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance on April 25-26, 2023, in Washington! Don’t miss the opportunity to stay current with the...more
In addition to compliance considerations under US sanctions associated with activities of U.S. persons, companies should also ensure that their compliance programs take into account the expansion under U.S. export controls of...more
While the pandemic has slowed down many things this year, it did not impede progress by the Department of Commerce’s Bureau of Industry and Security (“BIS”) in publishing various regulatory changes aimed at addressing...more
The Commerce Department’s Bureau of Industry Security (“BIS”) issued a final rule to restrict even further export licenses for National Security (“NS”) controlled items for China, Venezuela and Russia....more
Report on Supply Chain Compliance 3, no. 7 (April 2020) The United States Department of the Treasury’s Office of Foreign Assets Control has stayed busy during the coronavirus outbreak. The office made several new additions...more