January 7, 2021 - Policy Alerts

OFAC Issues Clarifying Guidance on Communist Chinese Military Companies Sanctions

On December 28, 2020, the Office of Foreign Assets Control (OFAC) at the United
January 6, 2021 - Policy Alerts

Proposed Rules for Transactions with Unhosted Virtual Currency Wallets

On 18 December, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of
January 6, 2021 - Policy Alerts

National Defense Authorization Act 2021: Landmark AML Reforms Pass Congress

In the most consequential update to the Bank Secrecy Act (BSA) since the 2001
November 20, 2020 - Policy Alerts

United States Prohibits Investment in Chinese Companies with Military Ties

On November 12, 2020, President Trump issued an Executive Order on Addressing the Threat
November 5, 2020 - Policy Alerts

Proposal to Revise Recordkeeping and Travel Rule Requirements Poses Implementation Challenges for FIs and VASPs

The U.S. Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the
October 30, 2020 - Policy Alerts


Beginning on October 21, 2020, the Financial Action Task Force (FATF) held its three-day
October 6, 2020 - Policy Alerts

United States Attempts UN Sanctions Snapback on Iran

After the United Nations Security Council (UNSC) declined to extend a conventional arms embargo
September 28, 2020 - Policy Alerts

ICIJ Leaked SAR Investigation Highlights Opportunity for BSA/AML Reform

Press reporting on thousands of leaked Suspicious Activity Reports (SARs) filed by financial institutions
September 24, 2020 - Policy Alerts

China Announces “Provisions on the Unreliable Entity List”

On September 19, China’s Ministry of Commerce (MOFCOM) released an administrative order—the “Provisions on
September 10, 2020 - Policy Alerts

New Interagency Advisory on North Korean Missile Procurement

On September 1, the U.S. Departments of State, Treasury, and Commerce issued a North


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