On December 19, 2018, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced its plan to lift sanctions on three Russian entities for agreeing to distance their businesses from a prominent oligarch.  Specifically, OFAC informed Congress of its intention to terminate sanctions on entities previously designated for being owned and controlled by sanctioned oligarch Oleg Deripaska (“Deripaska”). Treasury Secretary Steven Mnuchin announced that En+ Group plc (“En+”), UC Rusal plc (“Rusal”), and…

On December 3, 2018, a U.S. government working group aimed at improving the effectiveness and efficiency of the BSA/AML regime issued a second joint statement, which focuses on innovative industry approaches to BSA/AML compliance.  This follows the working group’s first joint statement last month, which focused on BSA/AML resource sharing (as discussed in our prior blog post).  The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and the federal banking regulators (the Board of Governors…

On November 19, 2018, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued an advance notice of proposed rulemaking (“ANPRM”) seeking public comment on “criteria for identifying emerging technologies that are essential to U.S. national security.”[1]  The ANPRM was issued pursuant to the Export Control Reform Act of 2018 (“ECRA”), a law enacted in August 2018 that authorizes the Commerce Department (in coordination with other federal agencies) to issue regulations…

On November 19, 2018, a group of five U.S. federal and state prosecutors and regulators[1] announced that they had reached settlements with Société Générale (“SocGen”) under which SocGen will pay penalties totaling $1.34 billion in relation to violations of U.S. economic sanctions concerning Iran, Cuba, Sudan and other sanctioned countries  (collectively, the “Settlements”).  As noted prominently in the DOJ’s press release, the Settlements represent the second largest penalty ever imposed on a financial…

On October 11, 2018, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a lengthy “Advisory on the Iranian Regime’s Illicit and Malign Activities and Attempts to Exploit the Financial System,” (the “Iran Advisory”), which provides examples and typologies of the Iranian regime’s exploitation of financial institutions worldwide, and identifies a number of “red flags” intended to assist financial institutions in identifying malign Iranian activity.  According to FinCEN, the Iran Advisory is intended…

On October 5, 2018, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had entered into an approximately $5.3 million civil monetary settlement with JPMorgan Chase Bank, N.A. (“JPMC”) for apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. Part 515, the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560, and the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. Part 544.  At the same time, OFAC announced that…

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and the federal banking regulators have taken a small step towards improving the BSA/AML compliance framework for depository institutions.  These agencies issued a Joint Statement on Banks and Credit Unions Sharing Resources to Improve Efficiency and Effectiveness of Bank Secrecy Act Compliance (Joint Statement) on October 3, 2018 to address ways in which small banks and credit unions may enter into collaborative arrangements to share resources to…