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
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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Treasury Sanctions Tornado Cash and Turns Up Heat on Mixers
On August 8, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned virtual currency mixing service Tornado Cash, which OFAC said has been used to launder billions of dollars in virtual currency, including $455 million stolen by the Lazarus Group, a Democratic People’s Republic of Korea (“DPRK”) state-sponsored hacking group
Sanctions/Export Highlights [As of May 6, 2022]
Russia Sanctions: The UK designated 63 individuals this week, including several war correspondents embedded with Russian forces in Ukraine that work at Channel One, a major state-owned media outlet in Russia. The UK also designated one entity, Evraz PLC, a UK-incorporated holding company of a multinational steel manufacturing and mining company group. Additionally, the
Russia Sanctions/Export Highlights [As of March 10, 2022]
Russia Sanctions: The U.S., EU, and UK continue to apply pressure on Russia through new sanctions on oligarchs and politicians and restrictions on exports. A number of other countries have implemented similar measures and continue to widen the scope of such prohibitions as the invasion continues. On a more limited scale, Belarus has also
Virtual AML & OFAC Conference: Risk-Based Compliance and Due Diligence Requirements, the Pandora Papers and Emerging Risks to Flag Now
The American Conference Institute is hosting a Virtual AML & OFAC Conference for the Insurance Industry from January 19-20, 2022.
On January 19, 2022 at 12:30pm, Nicole Sayegh Succar, Counsel in Crowell & Moring’s New York Office, will be speaking on a panel with Matthew Saint, Group AML Officer/Deputy Group Chief Financial Crime Officer of
U.S., EU and UK Escalate Belarus Sanctions
On December 2, 2021, the United States, the European Union (“EU”), the United Kingdom (“UK”) and other allies took coordinated action to designate various individuals, entities, and aircraft connected to human rights abuses by Belarussian President Alexander Lukashenko and his regime. This builds on asset freezing actions by the U.S., UK, EU, and Canada earlier
Treasury Agencies Issue Virtual Currency Sanctions Compliance Guidance and Ransomware Trends Statistics
On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued its first-ever sanctions compliance guidance (the “OFAC Guidance” or “Guidance”) for the virtual currency industry. The Guidance represents a focused effort by OFAC to highlight sanctions risks present in the virtual currency industry, which has experienced tremendous growth
Office of Foreign Assets Control (OFAC) Issues License For the U.S. Government and U.S. Government Contractors for Humanitarian Assistance in Afghanistan
On August 25, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a License (the License) pursuant to OFAC’s Global Terrorism Sanctions Regulations (GTSR or SDGT Sanctions) and Foreign Terrorism Organizations Sanctions Regulations (FTOSR) following a request from the Department of State. Under Section 1 of the License, the U.S. Government,
FinCEN and CFTC Announce $100 Million in Regulatory Settlements With Foreign Cryptocurrency Exchange for BSA Violations and Failures to Register
On August 10, 2021, the Financial Crimes Enforcement Network (“FinCEN”) and the Commodity Futures Trading Commission (“CFTC”) jointly announced $100 million in civil settlements with five entities responsible for the operations of BitMEX, a foreign peer-to-peer convertible virtual currency (“CVC,” or cryptocurrency) derivatives exchange. FinCEN said that the settlement represents FinCEN’s first enforcement action against