The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has published major revisions to its humanitarian authorizations and other general licenses under the North Korean Sanctions Regulations (“NKSR”), which took effect on February 16, 2024. These regulatory
International Compliance Blog
The International Compliance Blog, published by Steptoe LLP, focuses on developments in international sanctions, export controls, and anti-money laundering regulations. It covers topics such as US and UK sanctions regimes, enforcement actions, regulatory proposals affecting financial institutions and investment advisers, and guidance on compliance risks related to global trade and financial transactions. The blog also discusses government policies on export controls, voluntary self-disclosure programs, and the impact of sanctions on specific sectors like oil shipping and financial markets. It serves as a resource for understanding compliance obligations and enforcement trends in the context of international economic sanctions and regulatory frameworks.
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OFSI Publishes Update on New Russia Sanctions Reporting Requirements
The UK government introduced new reporting requirements under The Russia (Sanctions) (EU Exit) Regulations 2019 (“Russia Regulations”) in December 2023, with the goal of strengthening transparency in relation to assets frozen under the regime and assisting HM Treasury’s Office of…
Asia Pacific 2023 Anti-Corruption Rankings: Transparency International’s CPI and the TRACE Bribery Risk Matrix
By Wendy Wysong & Ali Burney
Asia Pacific (APAC) countries continue to “stagnate” in their rankings in 2023, only minimally above the global average, with most well below, according to two anti-corruption due diligence tools, TRACE’s 2023 Bribery Risk Matrix (TRACE Matrix) and Transparency International’s 2023…
UK NECC Publishes Amber Alert on Sanctions Evasion in the Art Storage Sector
The UK’s National Economic Crime Centre (“NECC”) recently issued an amber alert concerning the sanctions evasion, money laundering, and trafficking in cultural property risks presented to UK industries linked to artwork storage facilities and the art storage sector (the “Amber…
Potential new SAR-like Reporting Requirements for Certain U.S. Real Estate Transactions
By Jack Hayes & Jim Carolan
On February 8, 2024, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (2024 NPRM) about Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) regulations concerning persons involved in…
Commerce Proposes Significant New Regulations on AI Training and IaaS Providers
By Evan Abrams & Jack Hayes
In a recent proposed rule, the Department of Commerce has taken additional steps toward imposing significant regulations on infrastructure as a service (IaaS) providers, including providers engaged in training certain large AI models. The notice of proposed rulemaking (NPRM…
BIS Makes Further Changes to Administrative Enforcement, But Questions Remain
On January 16, 2024, the Assistant Secretary for Export Enforcement at the Department of Commerce’s Bureau of Industry and Security (BIS) issued a memorandum, announcing that:
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Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act Are Now In Effect
As of January 1, 2024, the Corporate Transparency Act (CTA) is effective, impacting millions of entities. On September 30, 2022, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published a final rule to implement the beneficial ownership…
The Top Ten Asia-Pacific FCPA Enforcement Actions of 2023
Enforcement of the Foreign Corrupt Practices Act (FCPA) in 2023 has been described as a lull, a continued downward trend, or a slump, but that may be “bullsh*t,” to quote an FCPA academic. However they are described, the 2023 FCPA…
New Secondary Sanctions Target Non-US Banks That Engage in Transactions with Russia’s Military-Industrial Base
On December 22, 2023, President Biden issued a new Executive Order (“EO”) 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities” which amended EOs 14024 and 14068. These amendments introduce the authority to impose secondary sanctions with…