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President Trump Announces Changes to Cuba Sanctions Program

What Americans traveling to Cuba should know about the recent changes to the Cuba sanctions program

On June 16, President Trump announced two impending, significant changes to the Cuba sanctions program, which will impact U.S. persons traveling to Cuba. In general, to travel to Cuba a U.S. person must fit within one of 12 categories authorized by OFAC. Individual people-to-people travel, which was under the general category of educational activities and […]

OFAC Fines Barclays Bank Over Shadow Blocked Entities

Barclays Bank Fined by OFAC for Shadow Blocked Entities

Barclays Bank Pays Millions to Settle Sanctions Violations Involving Shadow Blocked Entities On February 8, 2016, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement between the agency and Barclays Bank Plc regarding apparent violations of the Zimbabwe Sanctions Regulations (ZSR). Specifically, Barclays (including its New York branch), processed […]

FATF Report: Money Laundering Through the Physical Transportation of Cash

FATF Money Laundering Charges Through the Physical Transportation of Money

On November 30, 2015, the Financial Action Task Force (FATF) issued its latest report, entitled: Money Laundering Through the Physical Transportation of Cash.  For those who may be unfamiliar with the FATF, it is an independent inter-governmental body that develops and promotes policies to protect the global financial system against money laundering, terrorist financing, and […]

U.S. Secondary Sanctions System Part 3

Secondary Sanctions System in the U.S.

Impact on European Banks and Companies Click Here For Part 2 As stated in Part 1 of this series, the secondary sanctions system also impacts European companies, and this is through Executive Order 13608 signed by President Obama on May 1, 2012.  This Order gave to the Department of the Treasury the authority to impose […]

U.S. Secondary Sanctions System Part 2

Addresses Terrorist Finance Elimination and Legitimate Transaction and Family Remittance Enhancement

Impact on European Banks and Companies Click Here For Part 1 Click Here For Part 3 Executive Order 13622, signed by President Obama, allows the possibility of imposing sanctions against any foreign financial institutions conducting or facilitating any significant financial transaction with the Iranian state oil companies, for the purchase of petroleum or petrochemical products.[1] […]

GTO Issued Against 700 Businesses to Curb Money Laundering in Miami

Geographic Targeting Order Issued Against Miami Businesses

FinCEN: Geographic Targeting Order Issued Against ~700 Miami Businesses; Requires Implementation of Elevated Anti-Money Laundering Controls. On April 15, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) imposing additional anti-money laundering controls against businesses in Miami that export electronics.  This rarely utilized authority was last […]

Syria Sanctions: OFAC Issues New General License Authorizing Publishing-Related Transactions

Publishing Transactions in Syria Authorized by OFAC

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) commonly issues general licenses to sharpen and fine tune its country-based sanctions programs to minimize unintended consequences.  On April 13, 2015, OFAC issued a new general license in the Syrian Sanctions Regulations, promulgated pursuant to Executive Order 13338.  This new general license authorizes […]

Largest Settlement for OFAC Violations

OFAC Sanction Violations Bring Largest Settlement Ever

According to the Department of the Treasury, its Office of Foreign Assets Control (OFAC) has reached the largest ever settlement, totaling $963 million, for OFAC sanctions violations.

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