On September 20, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control designated the Central Bank of Iran, the National Development Fund of Iran, and the Etemad Tejarat Pars Co. under Executive Order 13224, OFAC’s counter-terrorism authority (E.O. 13224). The U.S. pointed to attacks on Saudi Arabia’s oil fields as the catalyst for this designation. With respect to the Central Bank of Iran’s counter-terrorism designation, OFAC finds that the Central Bank of Iran…

On September 9, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) published amendments to the Cuban Assets Control Regulations (the “Cuba Sanctions”) to limit “U-turn” transactions and remittances. “U-turn” transaction is a reference to a Cuba Sanctions authorization (31 CFR § 515.584(d)) for banking institutions subject to U.S. jurisdiction to process transactions prohibited by the Cuba Sanctions if the transaction originated and terminated outside the United States, and the originator and…

On August 28, 2019 the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced the launch of a Global Investigations Division (GID), which will be led by Matthew Stiglitz, a former Principal Deputy Chief in the Department of Justice’s (DOJ’s) Criminal Division. The GID replaces and expands on FinCEN’s Office of Special Measures (OSM), which was a part of FinCEN’s Enforcement Division. On September 3, 2019, FinCEN also announced that AnnaLou Tirol would depart…