Over the last week, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued two updated advisories, as well as issued a series of new designations of Specially Designated Nationals (SDNs), highlighting the sanctions-related risks for, and the focus on, the shipping community. Taken together, they provide important guidance for
FinCEN and Federal Banking Agencies Encourage Innovative Approaches to BSA/AML Compliance
On December 3, 2018, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network (FinCEN), the National Credit Union Administration, and the Office of the Comptroller of the Currency (together “the agencies”), issued a joint statement encouraging banks
Agencies Issue Joint Statement on Banks’ Resource Sharing and Collaborative Arrangements
On October 3, 2018, the Financial Crimes Enforcement Network (FinCEN), the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC) (collectively, “the Agencies”) issued a statement addressing instances in which banks can collaborate
Banking Regulators Issue Exemption from CIP Requirements for Premium Finance Loans
On September 28, 2018, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency (collectively the Federal Banking Agencies or FBAs), with the concurrence of the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), issued an interagency order
New Obligation for Belgian Entities to Register Ultimate Beneficial Owners by March 31, 2019
In 2015, the European Union adopted its Fourth Anti-Money Laundering Directive, which imposed on Member States the obligation to establish a register containing the details of the ultimate beneficial owners (UBOs) of corporate and other legal entities within the European Union (the so-called UBO register). By way of the Act of September 18, 2017, the
Now Available On Demand – Webinar Trade in 2018 – What’s Ahead?
On April 19, Crowell & Moring’s International Trade Attorneys hosted a webinar on “Trade in 2018 – What’s Ahead?”
Please click here to register and view the webinar on demand.
Summary
From the Section 232 national security tariffs on steel and aluminum imports to the ongoing NAFTA re-negotiation, the Trump administration is seeking to implement
Venezuela Update: Florida Divestment and New Measures in Panama and Switzerland
The last week of March has brought new measures against Maduro’s regime from the U.S., Europe, and Latin-America. While Switzerland has aligned with European Union (EU) sanctions, Panama has included Venezuelan government officials and several companies in their Politically Exposed Persons’ (PEPs) list. The State of Florida has also enacted divestment laws targeting Venezuela.
Florida
HM Treasury Issues Advisory Notice – Enhanced Due Diligence Required for Higher Risk Jurisdictions
The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 require the UK regulated sector to apply enhanced customer due diligence to high-risk countries.
In response to recent statements from the Financial Action Task Force (FATF), HM Treasury advises firms to consider the following:
| Consider as high risk and apply counter measures and |
FinCEN’s New Advisory on Cyber Crime Could Expand Suspicious Activity Reporting Requirements
On October 25, 2016, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a new Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime as well as a related list of Frequently Asked Questions (FAQs).
The Advisory provides guidance to financial institutions on FinCEN’s expectations with regard to: (1) reporting cyber-enabled crime and