On November 19, 2018, a group of five U.S. federal and state prosecutors and regulators[1] announced that they had reached settlements with Société Générale (“SocGen”) under which...
On November 5, 2018, the United States completed the process of fully re-imposing sanctions related to Iran that were waived or lifted pursuant to the Joint Comprehensive Plan of Action (...
The Treasury Department has issued temporary regulations establishing a pilot program to implement two provisions of the Foreign Investment Risk Review Modernization Act of 2018 that did ...
On October 11, 2018, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a lengthy “Advisory on the Iranian Regime’s Illicit and Malign Activities a...
On October 5, 2018, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had entered into an approximately $5.3 million civil monetary settlement wi...
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...
