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On October 21, 2021, the Bureau of Industry & Security (BIS) of the US Department of Commerce issued a significant interim final rule (the Interim Rule). The Interim Rule, reflecting an overall recent government emphasis on cybersecurity and ransomware issues, establishes new export controls for “cybersecurity items” such as intrusion software and network surveillance equipment … Read more
On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an industry-specific brochure entitled, “Sanctions Compliance Guidance for the Virtual Currency Industry” (the “OFAC Guidance”). According to a press release, the OFAC Guidance “outlines sanctions compliance best practices tailored to the unique risks posed in this dynamic space, … Read more
In a special podcast cross over event, the Designated team joins The Bettor’s Verdict to discuss the Impact of Crypto on Sanctions and AML Laws in the United States. In this episode, Designated host Jonathan Cross, is joined by The Bettor’s Verdict host Steve Jacobs, and Herbert Smith Freehills Partner John O’Donnell. Jonathan, Steven and … Read more
On September 17, 2021, the President signed Executive Order (“E.O.”) 14046, imposing sanctions on certain persons with respect to the humanitarian and human rights crisis in Ethiopia. According to a Fact Sheet issued by the White House, the conflict in Ethiopia “has sparked one of the worst humanitarian and human rights crises in the world, … Read more
On September 9, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) entered a settlement agreement with NewTek, Inc. (“NewTek”), headquartered in San Antonio, Texas. According to a press release, NewTek agreed to pay $189,483 to settle its potential civil liability for 52 apparent violations of the Iranian Transactions and Sanctions … Read more
On September 21, 2021, the Office of Foreign Assets Control (“OFAC”) of the Treasury Department issued an Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments (“Updated Advisory”), which warns of the sanctions risks of making or facilitating ransomware payments and provides expanded guidance on steps that companies may take to mitigate ransomware risk. … Read more
Now that the Taliban controls Afghanistan, many businesses with economic interests or investments in the country are reevaluating potential sanctions risks. Indeed, a former OFAC official explained that, “[t]his is a new world,” and that he could not “think of any case in which a terrorist group that’s already designated became the power in charge … Read more
In this episode, Jonathan Cross, Brittany Crosby-Banyai and Dan Hudson discuss the history of the Iran sanctions program under the Iranian nuclear deal, known as the Joint Comprehensive Plan of Action (“JCPOA”). They also analyze the mechanisms by which sanctions were re-imposed when the US left the agreement. These considerations offer insight as to the … Read more
On August 27, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) entered a settlement agreement with First Bank SA (“First Bank”), located in Romania, and its U.S. parent company, JC Flowers & Co. (“JC Flowers”). According to a press release, the companies agreed to pay $862,318 to settle potential civil … Read more
