Jonathan Poling

2 months ago | mondaq.com | Jonathan Poling |Kevin Wolf |Thomas Krueger |John Babcock

On January 20, 2025, President Trump signed the National Security Presidential Memorandum (NSPM-1), which lays out the framework for how the National Security Council (NSC) will be organized under his administration.1 The Trump NSC framework is different from Biden's, which was articulated in NSM-2, in some ways.2 In a change from Biden administration processes, NSPM-1 merges the Homeland Security Council (HSC) and the NSC on certain agreed-to topics, providing more discretion about who can...

2 months ago | akingump.com | Jonathan Poling |Kevin Wolf |Thomas Krueger |John Babcock

On January 20, 2025, President Trump signed the National Security Presidential Memorandum (NSPM-1), which lays out the framework for how the National Security Council (NSC) will be organized under his administration.1 The Trump NSC framework is different from Biden’s, which was articulated in NSM-2, in some ways.2 Key Takeaways: In a change from Biden administration processes, NSPM-1 merges the Homeland Security Council (HSC) and the NSC on certain agreed-to topics, providing more discretion...

May 7, 2024 | mondaq.com | Mahmoud Baki Fadlallah |Ryan Fayhee |Alexis Guinan |Jonathan Poling

On April 24, 2024, President Biden signed into law H.R. 815, a significant foreign aid legislative package that also included the 21st Century Peace Through Strength Act (the Act), a bill introduced in the House that includes multiple U.S. sanctions-related provisions.

Apr 26, 2024 | mondaq.com | Mahmoud Baki Fadlallah |Alexis Guinan |Jonathan Poling |Melissa Schwartz

On April 17, 2024, based on a determination by the U.S. government that Nicolás Maduro and his representatives "have not fully met the commitments made" with respect to upcoming Venezuelan elections, the U.S. Department of the Treasury's OFAC replaced GL 44, which had previously authorized transactions related to oil or gas sector operations in Venezuela, with a limited wind-down authorization, provided in GL 44A.

Feb 14, 2024 | lexology.com | Peter Altman |Michael Asaro |Brian Daly |Jason Daniel |Katherine Goldstein |Alexis Guinan | +11 more

Key PointsOn February 13, 2024, FinCEN issued an NPRM that seeks to include certain investment advisers in the definition of “financial institution” under the BSA. As described in the NPRM as well as in FinCEN’s fact sheet, RIAs and ERAs would be required to implement risk-based AML/CFT programs, file SARs with FinCEN, fulfill certain recordkeeping requirements and fulfill other obligations currently applicable to financial institutions subject to the BSA and FinCEN’s implementing regulations.