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The Trump Administration and Sanctions

Posted in Economic Sanctions

During his presidential campaign, President-Elect Donald Trump made few concrete statements regarding sanctions policies. However, it is possible to identify some areas where things might change significantly. Iran: President-Elect Trump has said that he would immediately scrap the Joint Comprehensive Plan of Action (JCPOA) with Iran. The JCPOA has been described as a political commitment… Continue Reading

The Outlook For Sanctions and Export Controls in the Next Administration

Posted in Economic Sanctions, Export Controls

With the presidential election fast approaching, businesses may be wondering what the next administration is likely to do with respect to sanctions and export controls. If Secretary Clinton is elected, the most likely path is a continuation in general of the current policies. If Donald Trump is elected, the prospects are much less clear. And… Continue Reading

Schlumberger Fine Emphasizes Need to Insulate U.S. Persons from Activities Involving Sanctioned Countries

Posted in Compliance, Economic Sanctions

Schlumberger Oilfield Holdings, the world’s largest oil field services company, has pleaded guilty to one count of conspiring to violate U.S. economic sanctions against Iran and Sudan. As part of its plea arrangement, Schlumberger has agreed to pay a fine of $232.7 million, and three years of corporate probation. The plea agreement concludes an investigation… Continue Reading

Commerzbank Fined $1.45 Billion For Sanctions And Money Laundering Violations

Posted in Anti-Money Laundering, Compliance, Economic Sanctions, National Security

Commerzbank AG, the second-largest bank in Germany, is the latest in a series of foreign banks to be fined hundreds of millions of dollars for violations of U.S. sanctions and anti-money laundering (AML) laws. Commerzbank and its New York branch have agreed to pay fines and forfeitures totaling $1.45 billion, including $259 million imposed by… Continue Reading

New Sanctions May Make Business With Venezuela More Complicated

Posted in Compliance, Economic Sanctions, Export Controls, Trade Policy

On March 9, 2015, President Obama issued a new Executive Order instructing the freezing of the assets and the denial of entry into the United States of seven officials of the Venezuelan government. U.S. persons, including U.S. citizens, permanent residents, and companies, are prohibited from engaging in any transactions with the designated officials, and must… Continue Reading

Identifying UBOs: The Conflict Between FINCEN and OFAC

Posted in Anti-Money Laundering, Compliance, Economic Sanctions

Identifying who the hidden owners of an entity may be is a key step in combatting money laundering and terrorist financing and complying with U.S. sanctionslaws. For banks in particular, this means identifying the ultimate beneficial owners (UBOs) of customers who are legal entities. Typically, banks will try to identify everyone holding some specified percentage… Continue Reading

Foreign Exchange Trading: The Need For Internal Controls

Posted in Anti-Money Laundering, Economic Sanctions

On November 12, 2013, the Commodity Futures Trading Commission (CFTC) announced that it had imposed fines totaling $1.4 billion on five major international banks in connection with the alleged manipulation of foreign exchange benchmark rates. In each case, the CFTC asserted that individual traders within the banks had colluded to move benchmark foreign exchange rates,… Continue Reading

FinCEN Clarifies that Anti-Money Laundering Rules Apply to Virtual Currencies

Posted in Anti-Money Laundering

Companies involved in virtual currency business must consider anti-money laundering compliance.  Dealing in virtual currencies, like Bitcoin, could trigger obligations under the Bank Secrecy Act (BSA), such as the duty to report suspicious activity. This week, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) determined that, in two cases, businesses dealing in virtual… Continue Reading

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