Economic Sanctions & Anti-Money Laundering
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Our team advises U.S. and non-U.S. clients across industries on their most sensitive U.S. economic sanctions and Bank Secrecy Act/anti-money laundering (BSA/AML) issues. With our preeminent regulatory defense and white collar experience, we are uniquely positioned to assist clients in responding to regulator inquiries, examinations and subpoenas; conducting internal investigations; and handling matters that develop into multi-agency civil and criminal investigations. Our practice also encompasses regulatory advice, compliance counseling and transactional due diligence.
FATF “Gray Lists” Turkey, Citing Concerns with Turkey’s Banking and Real Estate Sectors and Potential Terrorism Financing
The FATF recently added Turkey to its “Gray List”—a list of countries that FATF has determined to have “strategic deficiencies” in their anti-money laundering (AML) and counter-terrorism financing (CFT) laws and regulations.
President Biden recently issued an executive order revising and superseding President Trump’s 2020 executive order that created the “Communist Chinese Military Companies” (CCMC) sanctions program.
- Economic Sanctions & AML
- Financial Institutions
- H. Christopher Boehning
- Jessica S. Carey
- Christopher D. Frey
- Michael E. Gertzman
- Roberto J. Gonzalez
- Brad S. Karp
- Xiaoyu Greg Liu
- Mark F. Mendelsohn
- Richard S. Elliott
- Rachel Fiorill
- Robyn E. Bernstein
- Jennifer Gilbert
- Aaron E. Haier
- Leah Hibbler
- Carly Lagrotteria
- Jacobus J. Schutte
- Katherine S. Stewart
- Jake E. Struebing
- Sylvia Sui
- Joshua R. Thompson
- Andrew H. Trinker
- Courtney Wiesner
- Braeshaun Dozier
- Emily M. Glavin
In this annual review, we survey U.S. economic sanctions and anti-money laundering regulatory and enforcement developments in 2020 and provide an outlook for the year ahead under the new administration.
Litigation partner Roberto Gonzalez and counsel Rachel Fiorill served as contributing editors and authored two chapters in the International Comparative Legal Guide (ICLG): Sanctions 2021, published by the Global Legal Group Ltd., London.
Brad Karp, Roberto Gonzalez and Hilary Oran Co-Author Law360 Article on CFPB Policy Shift Regarding Abusive Acts
Firm Chairman Brad Karp, litigation partner Roberto Gonzalez and litigation associate Hilary Oran co-authored an article, “What CFPB Policy Shift Means For Scrutiny Of Abusive Acts,” that appeared in Law360.
OFAC Enforcement Action against U.S. Payments Company Shows the Importance of Robust Sanctioned Person and Location Screening
OFAC announced a settlement with the company for allowing persons in sanctioned jurisdictions and on OFAC's SDN List to engage in transactions.
The OCC Issues Guidance Confirming that National Banks and Federal Savings Associations May Hold Reserves for Certain Stablecoins
U.S. banks and federal savings associations may accept deposits that serve as reserves for stablecoin backed on a 1:1 basis by a single fiat currency in a hosted wallet.
Litigation partner Chris Boehning was featured in the latest episode of the Institute of International Bankers’ “Bank Talk” podcast series.
Litigation partner Roberto Gonzalez moderated a panel, “Sanctions and Security: What’s New at OFAC in 2020,” as part of the Institute of International Bankers’ two-day virtual seminar.
President Trump Signs the Hong Kong Autonomy Act into Law and Issues an Implementing Executive Order
President Trump recently signed the Hong Kong Autonomy Act (HKAA) into law and issued an executive order implementing the HKAA.
The UK Financial Conduct Authority recently ordered Commerzbank to pay more than £37 million penalty for years of anti-money laundering failures in systems and controls.
Industrial Bank of Korea Reaches $86 Million AML Resolution with DOJ, NY Attorney General, and NY DFS
The DOJ, the N.Y. Attorney General and the N.Y. Department of Financial Services (DFS) recently announced an $86 million resolution with Industrial Bank of Korea (IBK) in connection with criminal violations of the Bank Secrecy Act and violations of New York’s banking laws.
OCC Takes Unprecedented Enforcement Actions Against Eight Former Wells Fargo Executives, Including the Former Chairman & CEO, Head of the Bank, General Counsel, and Risk and Audit Executives
As the latest chapter in the aftermath of the Wells Fargo fake accounts scandal, the OCC announced enforcement actions against eight former Wells Fargo executives for their roles in the bank’s “systemic sales practices misconduct.”
The sudden and rapid rise of virtual currencies, coupled with the potential applications of blockchain and distributed ledger technologies across virtually all industries, has generated a wave of innovation, disruptive businesses and a modern digital economy. This series of white papers examines the new legal and regulatory issues in these areas that are cropping up every day.