The authors wish to thank Molly McKenna for her contributions to this post. On February 23, 2024, the Financial Action Task Force (“FATF”) removed the United Arab Emirates (“UAE”) from its list of jurisdictions under increased monitoring (the “Grey List”). As noted in our previous article (see here), FATF had intimated at its October 2023 … Continue Reading
Between October 25 and October 27, 2023, the Financial Action Task Force (“FATF”), an international policy-making and standard-setting body dedicated to combating money laundering and terrorist financing, held its third plenary meeting of the year (the “October Plenary”), at which it made important updates to its list of jurisdictions under increased monitoring, often externally referred … Continue Reading
The second half of 2023 saw eight enforcement actions from the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). These actions reflect a range of penalties, industries, sanctions programs, conduct, and lessons learned. Below are some highlights from OFAC’s enforcement releases and settlement agreements. Penalties OFAC imposed a total of $984,851,289.90 in penalties … Continue Reading
Earlier this year, we published a post on the first Tri-Seal Compliance Note (“First Note”) issued by the United States Department of Justice’s (“DOJ”) National Security Division (“NSD”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”).[1] When issuing the First Note, … Continue Reading
On March 2, 2023, the Department of Justice announced several new initiatives that prioritize the investigation and enforcement of economic sanctions evasion, export control violations, and similar economic crimes. Deputy Attorney General Lisa Monaco announced a “surge of resources to address a troubling trend: the intersection of corporate crime and national security.” In particular, DOJ’s … Continue Reading
The investigation and enforcement of potential sanctions violations by crypto exchanges is an area of focus in the US at present. The US Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) recent settlement with Kraken, a global virtual currency exchange, is the most recent OFAC case demonstrating the risks for virtual currency platforms … Continue Reading
On August 8, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned virtual currency mixer Tornado Cash for having laundered more than USD 7 billion worth of virtual currency since its founding in 2019. This includes over USD 455 million worth of stolen virtual currency associated with the Lazarus Group, … Continue Reading
“Russia should not benefit from European knowledge and expertise.” That is the view of European Commission (“EC”) President Ursula von der Leyen, who recently proposed an eighth package of sanctions against Russia in response to “escalation” in Ukraine. Among the “biting” new sanctions will be a wider ban on the provision of European services to … Continue Reading
The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, which is the authority for implementing financial sanctions in the UK, have published guidance to clarify how they will use their new powers to impose civil monetary penalties for sanctions breaches on a strict liability basis from Monday 15 June 2022. The full message … Continue Reading
Following a ruling issued last week by a federal judge in Texas, ExxonMobil Corporation (“ExxonMobil”) will not have to pay a previously issued penalty for contracting with Russia’s state-owned PJSC Rosneft Oil Company (“Rosneft”), since it was not provided fair notice by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) that … Continue Reading
Russian Duma Revisits Criminalization as Counter-sanction The Russian Duma is considering a bill that would prohibit media communications that reveal non-compliance with sanctions or facilitate imposition of sanctions and would also impose criminal penalties on those that disclose or transfer information to organizations “directly or indirectly” under the control of an “unfriendly state”, any company … Continue Reading
Anti-corruption has been a hot topic in Russia for some time. But recently, the Russian government has begun to take creative approaches in the fight against corruption. These initiatives are aimed at raising public awareness of corruption among the general public. What appears to be missing in this outreach is compliance guidance to companies in … Continue Reading
