Sanaa Bayyari

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FinCEN Requests Public Comments on Potential No-Action Letter Process

Thanks to our Summer Associate, Apollo Yong, for his work on this timely blog. On June 6, 2022, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury, issued an Advanced Notice of Proposed Rulemaking (“ANPRM”), requesting public comment on questions related to FinCEN’s implementation of a no-action letter process.[1] … Continue Reading

DOJ FCPA Opinion Encourages Corporate Disclosure

On January 21, 2022, the Department of Justice issued an opinion applying the Foreign Corrupt Practices Act to a Hollywood movie-like factual scenario relating to extortion and duress. The opinion is one of two FCPA opinions published within the last two years. Before those two opinions, DOJ had not published one since 2014. Publication of … Continue Reading

UAE’s New Executive Office of AML/CFT and Dubai’s New Specialized Money Laundering Court

On August 22, 2021, at the directive of His Highness Sheikh Mohammed bin Rashid al Maktoum, Vice President and Prime Minister of the UAE and Ruler of Dubai, Dubai Courts announced the establishment of a specialized new court that will focus on combating money laundering.  The announcement comes just months after the UAE Cabinet approved … Continue Reading

OFSI Russian Sanctions Penalty; Foreshadows Increasing UK Enforcement?

On March 31, 2020, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) levied its largest monetary penalty to date of GBP 20.47 million. OFSI penalized Standard Chartered for loans to Denizbank, a Turkish bank that was majority owned by Sberbank, a state-owned Russian bank.  Accordingly, those loans violated European Union restrictions on making certain … Continue Reading
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