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Mar 12, 2024 | 
lexology.com | L. Atkinson |Jessica Carey |John Carlin |David C. Fein |Michael E. Gertzman |Roberto González | +10 more
On March 6, the Department of Commerce’s Bureau of Industry and Security (“BIS”), the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the Department of Justice (“DOJ”) issued their most recent ”tri-seal” compliance note (the “Compliance Note” or “the Note”).[1]The Compliance Note highlights that U.S. sanctions and export controls apply to non-U.S. persons, both companies and individuals, in a variety of circumstances.
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Feb 22, 2024 | 
miamiherald.com | David C. Fein
Fifty million passengers pass through Miami International Airport each year, some with a dark secret. Concealed in the confines of their hair curlers, medicine bottles and baby formula are thousands of illegally smuggled live birds, reptiles and amphibians. Although the concept of wildlife trafficking may feel like a faraway problem, it is closer than many think. The U.S., Canada and Mexico are crucial destination, transit and source hubs for wildlife trafficking.
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Feb 21, 2024 | 
lexology.com | H. Christopher Boehning |Jessica Carey |John Carlin |David C. Fein |Michael E. Gertzman |Roberto González | +4 more
On February 13, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a proposed rule aimed at “keep[ing] criminals and foreign adversaries from exploiting the U.S. financial system and assets through investment advisers” (the “Proposed Rule”).[1] The Proposed Rule would require SEC-registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) (together, “Covered Investment Advisers”) to establish anti-money laundering/countering the...
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Nov 14, 2023 | 
lexology.com | Jessica Carey |John Carlin |David C. Fein
On November 6, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) jointly issued a notice (the “Notice”) announcing a new Suspicious Activity Report (“SAR”) key term, “FIN-2023-GLOBALEXPORT,” that financial institutions should reference when reporting potential efforts by individuals or entities seeking to evade U.S. export controls.[1] Overview of the FinCEN-BIS Notice Pursuant to...
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Oct 24, 2023 | 
lexology.com | H. Christopher Boehning |Jessica Carey |John Carlin |David C. Fein
In October 17, 2023 remarks, Treasury Under Secretary for Terrorism and Financial Intelligence Brian Nelson, signaled that Treasury would build on its “long-standing fight against the funding of Hamas” through “urgent and immediate steps”.[1] Under Secretary Nelson stated that Treasury is closely monitoring Hamas’s fundraising, whether through “surreptitiously accessing the formal financial system” or through the “use [of] virtual assets to raise and move funds” as a means “to circumvent the...
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Oct 4, 2023 | 
lexology.com | H. Christopher Boehning |Jessica Carey |John Carlin |David C. Fein |Michael E. Gertzman |Roberto Gonzalez | +6 more
On September 21, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $9,618,477 settlement agreement with 3M Company (“3M”), a global manufacturing company based in Minnesota, regarding 54 apparent violations of OFAC’s Iran sanctions regulations.[1] As described below, these apparent violations relate to an agreement that a 3M subsidiary entered into in 2016 and conduct that occurred between 2016 and 2018.[2] 3M voluntarily disclosed the matter to...
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Sep 14, 2023 | 
lexology.com | Jessica Carey |John Carlin |David C. Fein |Michael E. Gertzman |Roberto Gonzalez |Roberto J. González | +5 more
On September 11, 2023, the Department of Justice (“DOJ”) announced the appointment of two veteran prosecutors, Ian Richardson and Christian Nauvel, to serve as the first Chief Counsel and Deputy Chief Counsel for Corporate Enforcement, respectively, in the National Security Division.[1] The new Chief and Deputy Chief Counsel have collectively served as lead prosecutors on significant prosecutions involving corporations alleged to have committed national security crimes, including in United...
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May 22, 2023 | 
lexology.com | H. Christopher Boehning |Jessica Carey |John Carlin |David C. Fein
On April 25, 2023, the U.S. Department of Justice (“DOJ”) reached a resolution with British American Tobacco (“BAT”) and its subsidiary British American Tobacco Marketing Singapore (“BATMS”) to pay combined penalties and fines of $629 million to resolve charges of bank fraud and sanctions violations.[i] The charges arose from an alleged scheme from 2009 until 2017 in which BAT and BATMS used front companies to cause U.S. banks to process at least 280 wire transfers, totaling $341 million in...
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May 1, 2023 | 
lexology.com | H. Christopher Boehning |Jessica Carey |John Carlin |David C. Fein |Michael E. Gertzman |Roberto Gonzalez | +4 more
On April 19, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an order imposing a $300 million civil penalty against California-based Seagate Technology LLC (“Seagate U.S.”) and Singapore-based Seagate International Headquarters Pte. Ltd.
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Mar 13, 2023 | 
mg.co.za | David C. Fein
Earlier this year, the United States treasury and South Africa’s treasury joined forces to combat illicit finance linked to wildlife crime. The language used by the US treasury secretary, Janet Yellen, — “follow the money” — has been the guiding mantra for more than six years at United for Wildlife, a global network led by Prince William to end the illegal wildlife trade.
