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
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 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
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
This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more
Sanctions compliance is challenging because of the changing nature of sanctions regulations and individuals identified as Specially Designated Nationals. With each new administration, foreign policy priorities are usually...more