Nicole Succar

Oct 15, 2024 | lexology.com | L. Atkinson |Jessica Carey |John Carlin |Roberto González |Brad S. Karp |Loretta Lynch | +7 more

On October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued guidance to financial institutions on “best practices” for compliance with the Export Administration Regulations (“EAR”), including General Prohibition 10.[1] The Guidance appears to mark the first time that BIS has formally indicated that U.S. and non-U.S. financial institutions could be the subject of enforcement actions by BIS for violating the export control regulations directly.

Oct 2, 2024 | lexology.com | L. Atkinson |Jessica Carey |John Carlin |Roberto González |Brad S. Karp |Loretta Lynch | +7 more

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) recently issued new regulations that will have significant impacts on the compliance obligations of persons subject to U.S. jurisdiction, and particularly financial institutions. First, OFAC issued a Final Rule that describes the types of non-public “tailored actions” it can take.

Sep 19, 2024 | lexology.com | H. Christopher Boehning |Jessica Carey |John Carlin |Andrew J. Ehrlich |Roberto González |Brad S. Karp | +7 more

On August 28, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a rule (the “Final Rule”) imposing new anti-money laundering/countering the financing of terrorism (“AML/CFT”) standards on certain investment advisers (“Covered Investment Advisers”).[1] The Final Rule finalizes a draft that FinCEN proposed in its February 2024 Notice of Proposed Rulemaking (“NPRM”), with certain changes as discussed below.[2] Although the Final Rule does not take...

Apr 15, 2024 | law360.com | Carlton Greene |Caroline Brown |Nicole Succar

ADVERTISEMENT Don't want ads? Subscribe or login now. By Carlton Greene, Caroline Brown and Nicole Succar (April 15, 2024, 5:09 PM EDT) -- On March 29, the U.S. Department of the Treasury's Financial Crimes Enforcement Network, issued a notice and request for information and comment,[1] or RFI, seeking comments on the Bank Secrecy Act's customer identification program rule....