The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and the federal banking regulators have taken a small step towards improving the BSA/AML compliance framework for...
The past two weeks have seen a number of developments with respect to U.S. sanctions relating to Russia, as the Trump administration has (1) taken additional steps to ameliorate adverse c...
In response to feedback from financial institutions, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Ruling granting exceptive relief (the R...
For the first time in over a decade, Congress has amended the statutory authority under which the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”)...
On August 6, 2018, President Trump issued Executive Order (“E.O.”) 13846, further implementing his May 8, 2018 decision to terminate the United States’ participation in the Joint C...
Recent actions by the United States Department of Justice (“DOJ”) against Chinese companies in the technology sector made headlines. DOJ has also recently issued subpoenas to Chinese...
On June 27, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced amendments to the Iranian Transactions and Sanctions Regulations (“ITSR”), 3...
The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has recently issued several new or amended Ukraine-/Russia-related General Licenses (“GLs”) and corres...
On May 11, 2018, the customer due diligence rule, 31 C.F.R. § 1010.230 (the “CDD Rule”), issued by the Financial Crimes Enforcement Network (“FinCEN”) became applicable two years...
On May 8, 2018, President Trump announced that he was terminating the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”) with Iran and issued a Nationa...
