Topic
Sanctions Compliance
109 published works
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)…
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…
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…
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…
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…
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…
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…
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…
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)…
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…