News, insight and market knowledge on regulatory and compliance issues from Schulte Roth & Zabel
OFAC continues to issue sanctions and associated guidance relating to a number of targeted jurisdictions. Starting with Iran, which has been the subject of new sanctions over recent months, and continuing with Venezuela, Ukraine, Nicaragua and Cuba, this Alert sets forth a summary of the more recent sanctions developments.
Read more here.
On April 18, 2019, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury announced the assessment of a civil money penalty against Eric Powers for willfully violating the registration, program and reporting requirements of the Bank Secrecy Act and its implementing regulations. Between December 2012 and September 2014, Mr. Powers acted as…
On Oct. 3, 2018, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (collectively, the “Agencies”) issued an interagency statement regarding the sharing of Bank Secrecy…
In late June 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took action on a number of fronts, including re-implementing stricter sanctions against Iran, issuing detailed sanctions regulations under the Global Magnitsky Human Rights Accountability Act (“Global Magnitsky Act”) and easing sanctions against Sudan. Firms that engage in business that…
On Aug. 25, 2015, the Financial Crimes Enforcement Network (“FinCEN”) issued for public comment a proposed rule (the “Proposed Rule”) requiring investment advisers registered with the SEC (“RIAs”) to establish anti-money laundering (“AML”) programs and report suspicious activity to FinCEN pursuant to the Bank Secrecy Act (“BSA”).
The long-anticipated Proposed Rule arrives nearly seven years…
On Dec. 18, 2014, the Financial Crimes Enforcement Network issued a first-of-its-kind $1-million assessment against the former chief compliance officer and senior vice president of government affairs at MoneyGram International Inc. Separately, on Dec. 22, 2014, Bank Leumi USA and Bank Leumi Le-Israel, B.M. entered into a consent order with the New York State Department…
On Dec. 18, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued a first-of-its-kind $1-million assessment against the former chief compliance officer and senior vice president of government affairs at MoneyGram International Inc. FinCEN determined that the CCO “willfully violated” the requirements to: (1) “implement and maintain an effective anti-money laundering program;” and (2) “report suspicious…
The U.S. Securities and Exchange Commission (“SEC”) on May 20, 2015 announced a settlement with global resources company BHP Billiton over allegations that BHP Billiton violated the Foreign Corrupt Practices Act (“FCPA”) by providing luxury travel packages to foreign government officials and their spouses at the 2008 Beijing Olympic Games. The settlement, imposed through a…
The United States and others have imposed economic sanctions and issued anti-money laundering advisories in the wake of the growing political tensions between the United States and Russia over the fate of Ukraine. Click here for a summary of the actions taken by authorities to date and discusses compliance implications for investment funds. Fund managers…
On Nov. 14, 2012, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) jointly issued A Resource Guide to the U.S. Foreign Corrupt Practices Act (the “Guide”), available at http://www.justice.gov/iso/opa/resources/29520121114101438198031.pdf. The 120-page Guide provides a detailed analysis of the FCPA from the perspective of the government agencies charged with enforcing it.…
