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Topic

Sanctions Compliance

109 published works

  1. Global Investigations & Compliance Review

    OFAC and OFSI Publish Joint Guidance on US and UK Sanctions

    By Richard Gibbon, Hannah Laming, Adam Klauder, Katy Fisher, Elgun Ganizade

    On June 23, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) and His Majesty’s Treasury’s Office of Financial Sanctions Implementation (OFSI) published joint guidance (Guidance)…

  2. Dispute Resolution Blog

    Indirect Structures, Ownership Ties, and Regulatory Expectations: The Expanding Reach of Sanctions Compliance

    By Sara Sundaram, Irene Sarkar, Nikunj Agarwal

    Summary: With global regulators intensifying efforts to enforce sanctions, particularly concerning indirect or inadvertent breaches, Indian entities now face an elevated level of compliance risk — one that extends far…

  3. Dispute Resolution Blog

    How OFAC’s Latest Guidance Changes the Sanctions Compliance Landscape – Part II

    By Nikhil Varshney, Kritika Angirish

    Summary: Part II draws on recent enforcement actions to illustrate how OFAC applies this approach in practice. It highlights the heightened expectations placed on professional service providers and explains why…

  4. Sanctions & Export Controls Update

    UK Financial Conduct Authority publishes report indicating that financial institutions must do more to prevent sanctions breaches: key takeaways

    By Tristan Grimmer (UK), Mark Simpson (UK), Sven Bates (UK), Caitlin McErlane (UK), Philip Annett (UK), Julian Godfray (UK), Johanna Asplund (UK)

    On 28 May 2026, the UK Financial Conduct Authority (“FCA”) published a detailed report outlining steps that financial institutions take to comply with sanctions requirements, including examples of good and…

  5. Global Regulation Tomorrow

    FCA publishes findings from a review of sanctions systems and controls in firms

    By Simon Lovegrove (UK), Charlotte Carnegie

    On 28 May 2026, the Financial Conduct Authority (FCA) published its findings in relation to financial firms’ controls, highlighting good and poor practices and areas for improvement to support better…

  6. The CLS Blue Sky Blog

    Sullivan & Cromwell Discusses FinCEN, OFAC Proposed Rule on Anti-Money Laundering and Sanctions-Compliance Requirements

    By Charles C. Gray, Zachary K. Goldman, Manon T. Scales, Jordan M.H. Wish, Michael S. Loughlin

    On April 8, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) jointly issued a notice of proposed rulemaking…

  7. Sanctions & Export Controls Update

    US Treasury Department Proposes Rule to Implement GENIUS Act’s Anti-Money Laundering and Sanctions Compliance Program Requirements for Stablecoin Issuers

    By Terence Gilroy (US), Alexandre (Alex) Lamy (US), Rob O'Brien (US)

    On April 8, 2026, the US Department of the Treasury’s (“Treasury“) Financial Crimes Enforcement Network (“FinCEN“) and the Office of Foreign Assets Control (“OFAC“) issued a joint proposed rule (“Proposed…

  8. Dispute Resolution Blog

    Sanctions Compliance Beyond the 50% Rule: A Practical Guide for Indian Businesses

    By Sara Sundaram, Nikunj Agarwal, Irene Sarkar

    Summary: The 50% ownership rule has always been the cornerstone of sanctions compliance offering apparent certainty to entities navigating complex cross-border transactions. However, in recent years, global regulators have started…

  9. International Trade Law

    Senate Committee Advances Bill to Shield U.S. Companies from Foreign Judgment Enforcement in the United States Relating to U.S. Sanctions Compliance

    By Anand Sithian, T. Michael Guiffre, Sophie Davis, Liesbeth Truyens, Nate Young

    On March 26, 2026, the Senate Judiciary Committee advanced S.2934, the Protecting Americans from Russian Litigation Act of 2025 (the Bill), introduced by Senators John Cornyn (R-TX) and Alex Padilla (D-CA)…

  10. School Law

    What the IMG Academy Enforcement Action Means for Schools: A Risk-Based Approach to OFAC Sanctions Compliance

    By Julie C. Fay, Alfredo G. Fernández, Tom Owen

    The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently announced a $1.7 million settlement agreement with IMG Academy (a Florida boarding school) to settle the school’s potential liability…