We recently shared an alert covering The National Defense Authorization Act for Fiscal Year 2021 (NDAA), which became law on January 1, 2021. The NDAA included significant reforms to the U.S. anti-money laundering and countering the financing of terrorism regime. Division F of the NDAA consists of the Anti-Money Laundering Act of 2020, which includes … Continue Reading
On October 18, 2021, the U.S. Department of the Treasury (“Treasury”) released the findings from its review of the economic sanctions administered and enforced by its Office of Foreign Assets Control (“OFAC”). During the review, Treasury met with individuals representing hundreds of sanctions stakeholders, including Members of Congress and their staffs, the private sector, foreign … Continue Reading
On June 7, 2021, the UAE Central Bank issued new guidance requiring all UAE financial institutions to file suspicious activity reports (SARs) or suspicious transaction reports (STRs) with the UAE’s Financial Intelligence Unit (FIU) using the goAML portal within 35 calendar days of detection of any conduct that they reasonably suspect may be linked to … Continue Reading
On April 20, 2020, the Industrial Bank of Korea (IBK) and its New York branch (IBKNY) (collectively, “the Bank”) entered into a Deferred Prosecution Agreement (DPA) with the U.S. Attorney’s Office for the Southern District of New York (SDNY), a non-prosecution agreement (NPA) with the New York Attorney General, and a Consent Order (the “Consent … Continue Reading
The National Security Division recently revised its policy on cooperation credit in order to align with other components of the U.S. Department of Justice. The changes, which are designed to “reassure companies,” are discussed in our client alert available here.… Continue Reading
The Securities and Exchange Commission (“SEC”) recently penalized a public company for violating U.S. economic sanctions. The violation cited the “books and records” and “internal controls” provisions of Securities Exchange Act of 1934 (the “Exchange Act”). With this unprecedented action, the SEC has put companies on notice that the Department of Justice (the “DOJ”) and … Continue Reading
In an earlier post, here, we examined Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organizations, the new Federal AML Law enacted by the United Arab Emirates (“UAE”) to ensure best practice anti-money laundering and counter-terrorist financing measures. In this post, we consider how the UAE’s two … Continue Reading
On September 26, 2019, a bipartisan group of eight Senators introduced the Illicit Cash Act[1], which, among other proposed reforms, would require certain companies to disclose beneficial ownership information to the Financial Crimes Enforcement Network (FinCEN) at incorporation and within 90 days of any change in beneficial ownership. Led by Sen. Mark Warner (D-VA), co-sponsors … Continue Reading
The Financial Action Task Force (FATF), an intergovernmental organization founded 30 years ago to develop and uphold policies to combat money laundering and terrorist financing, is conducting a peer review (or “mutual evaluation”) of the United Arab Emirates (UAE) this year. FATF last assessed the UAE in 2008, and found the country’s systems and frameworks … Continue Reading
