On July 27, 2020, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI), the office in Her Majesty’s Treasury responsible for administering UK sanctions, released Maritime Guidance: Financial sanctions guidance for entities and individuals (the UK Guidance). The UK Guidance warns those in the maritime sector about sanctions threats they face, identifies examples of illicit […]

On July 14, 2020, President Trump took additional actions to address China’s policies regarding Hong Kong. These actions follow last week’s designation of high-ranking Chinese officials for alleged human rights violations in the Xinjiang Autonomous Region (Xinjiang) in western China and have potentially significant implications for corporations, financial institutions, and the global banking system. Read […]

On June 24, 2020, the Financial Action Task Force (“FATF”) held its plenary meeting virtually. It was the final plenary of China’s presidency of FATF; Germany will now begin its two-year term. As part of the plenary outcomes, FATF released several documents, including a new report on the illicit financial networks that support illegal wildlife […]

The growing rigor of virtual asset service provider (VASP) regulation and supervision globally has strengthened the compliance focus of leading VASPs, increasing their access to the traditional financial system and to sophisticated financial services. Ongoing implementation of the recently revised Financial Action Task Force (FATF) standards for VASPs suggests growing regulatory convergence on common compliance […]

Summary In response to Beijing’s moves to impose a controversial national security law on Hong Kong, President Trump announced on May 27th a limited visa ban on Chinese students and possible future steps that could include sanctions on Chinese officials and financial institutions. The announcement followed Secretary of State Michael Pompeo’s certification to Congress that […]

On May 14, 2020, the U.S. Department of State, the U.S. Department of the Treasury and the U.S. Coast Guard jointly released a long-awaited “Sanctions Advisory for the Maritime Industry, Energy and Metals Sectors, and Related Communities” (the Advisory). The Advisory provides a comprehensive analysis of sanctions risks in the maritime sector and specific guidance […]

The United Nations and the United States Government have released significant reports that detail North Korea’s continued efforts to engage in wide-ranging sanctions evasion activity in support of its weapons of mass destruction and ballistic missile programs. On April 13, 2020, the United Nations Panel of Experts on North Korea (POE) released a report on […]

On March 31st the Financial Action Task Force (FATF)—the global AML/CFT standard-setting body and watchdog—announced that it has upgraded the United States for technical compliance with FATF Recommendation 10 following implementation of the U.S. Treasury’s new customer due diligence (CDD) requirements. FATF’s re-rating—from “partially compliant” to “largely compliant”—reflects a great deal of hard work and […]

The Financial Action Task Force (FATF) on February 21, 2020, reintroduced its call for countries to impose countermeasures to protect themselves from illicit finance threats emanating from Iran. The call for countermeasures will increase risk for financial institutions with exposure to Iran. This move follows repeated warnings from FATF that it would once again call […]

The Trump Administration on January 10, 2020, issued broad new secondary sanctions with respect to Iran’s construction, mining, manufacturing, and textiles sectors in an effort to target additional sources of revenue used by the Iranian regime, as well as with respect to additional members of the Iranian leadership.  The expansion of secondary sanctions authority to […]