On November 13, 2024, the U.S. Department of the Treasury’s (“Treasury’s”) Office of Foreign Assets Control (“OFAC”) updated its FAQs for insurers in a long-awaited move to modernize its published sanctions compliance guidance for the insurance industry. None of the industry-specific FAQs had been updated since January 2015, and many had not been amended in
Client Alert: New BIS Guidance Continues Trend of Enhanced EAR Compliance Expectations for Financial Institutions
In new guidance published on October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued recommendations about its expectations for financial institutions in complying with U.S. export control obligations.
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OFAC Issues Notice for New Reporting Requirements for Financial Institutions Under the Rebuilding Economic Prosperity and Opportunity (REPO) for Ukrainians Act
On July 23, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a notice about new reporting requirements (the OFAC Reporting Notice) under the Rebuilding Economic Prosperity and Opportunity for Ukrainians Act (REPO for Ukrainians Act). As discussed in our previous client alert, the REPO for Ukrainians Act authorizes
Pressure Rising: New U.S. and UK Sanctions and Export Controls Increase Risks for Lingering Russia Exposure, Indirect Evasion in the Supply Chain, and IT Support for Russia Operations
An overview on new Russian sanctions and export controls issued by the U.S. (OFAC and BIS) and the UK focusing on the Russian financial, military, and LNG industries.
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Aid and Sanctions: Ukraine, Israel, and Taiwan Aid Bill Expands U.S. Sanctions and Export Control Authorities
The latest U.S. foreign aid bill supporting Ukraine, Israel, and Taiwan enacted on April 24, 2024 enhances U.S. sanctions and export controls including expanding (1) the statute of limitations for sanctions violations; (2) the President’s authority to coordinate sanctions efforts with the European Union and the United Kingdom; (3) sanctions and export controls on Iran
FinCEN Proposes Delaying Some Beneficial Ownership Filing Deadlines and Releases Additional Guidance for Beneficial Ownership Information Reporting
In advance of the impending January 1, 2024 effective date for the U.S. Treasury Department, Financial Crimes Enforcement Network’s (“FinCEN’s”) beneficial ownership information (“BOI”) reporting requirements, FinCEN has proposed an extension of the reporting deadline for some reporting companies, and issued additional guidance regarding BOI reporting requirements, including a Small Entity Compliance Guide, a
DOJ, OFAC, and BIS Issue “Tri-Seal Compliance Note” Focusing on Voluntary Self-Disclosures
What You Need to Know
Pressure Mounting: United States and United Kingdom Impose New Sanctions and Export Controls on Russia
Following a meeting of the G7 Summit Leaders, on May 19, 2023, the United States and the United Kingdom announced a new round of sanctions and export controls against the Government of the Russian Federation (“Russia”) to continue their efforts against key sectors of Russia’s military-industrial base.
FinCEN Issues Guidance on the “Who, What, When” of Beneficial Ownership Information Reporting Requirements
On March 24, 2023, the Financial Crimes Enforcement Network (“FinCEN”) issued its first set of guidance documents for its beneficial ownership reporting requirements, which take effect on January 1, 2024.
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The United States Imposes New Sanctions and Export Controls Targeting Russia and Belarus, Issues Joint Compliance Guidance, and Announces Corporate Compliance with Sanctions and Export Controls as an Enforcement Priority
On February 24, 2023, the United States and other G7 nations announced a number of new sanctions and export control measures coinciding with the one-year mark of Russia’s military invasion of Ukraine. Shortly after these expansive sanctions and export controls were announced, the Departments of Justice (“DOJ”), the Treasury (“Treasury”), and Commerce (“Commerce”) issued their