Evan Abrams

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President Trump Delays Decision on Permanent Rollback of Sudan Sanctions

On July 11, 2017, President Trump issued an executive order (“new executive order”) delaying the Trump Administration’s decision on whether to make permanent broad Sudan sanctions relief instituted in the waning days of the Obama Administration. On January 13, 2017, President Obama issued Executive Order (“EO”) 13761, which waived a number of statutory provisions mandating … Continue Reading

BIS Amends EAR Based on Missile Technology Control Regime Plenary Agreements

On July 7, 2017, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule amending the Export Administration Regulations (“EAR”) based on the 2016 Missile Technology Control Regime (“MTCR”) plenary agreements. The MTCR is a multilateral export control regime designed to control the export of certain goods and technology that … Continue Reading

FATF Continues Suspension of Countermeasures Against Iran, but Call for Enhanced Due Diligence Remains

The Financial Action Task Force (“FATF”) has announced the continued suspension of countermeasures against Iran. FATF, the international standards setting body for anti-money laundering (“AML”) and combating the financing of terrorism (“CFT”), maintains a list of high-risk and non-cooperative jurisdictions that may be subject to calls for enhanced due diligence and countermeasures.  Iran was previously … Continue Reading

Banamex USA Forfeits $97 Million to Resolve Bank Secrecy Act Violations

Banamex USA (“BUSA”) has agreed to forfeit $97.44 million and enter into a non-prosecution agreement with the US Department of Justice (“DOJ”) to resolve Bank Secrecy Act (“BSA”) violations.  BUSA is owned by Citigroup Inc. and is a leading money transmitter specializing in sending remittances from the US to Mexico.  The agreement, announced on May … Continue Reading

Former MoneyGram CCO Settles with FinCEN and U.S. Attorney’s Office

On May 4, 2017, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury and the U.S. Attorney’s Office for the Southern District of New York announced an agreement with former MoneyGram Chief Compliance Officer Thomas Haider to settle claims under the Bank Secrecy Act (“BSA”). FinCEN initially assessed a $1 million … Continue Reading

OFAC Extends Belarus Sanctions Relief

On April 28, 2017, the U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) issued a general license extending sanctions relief, which authorizes U.S. persons to engage in certain transactions with nine Belarus-based entities that have been designated as Specially Designated Nationals (“SDNs”), as well as other entities in which the nine entities have … Continue Reading

Trump Administration Uses New Approach in Syria Sanctions Action

On April 24, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 271 employees of Syria’s Scientific Studies and Research Center (“SSRC”) pursuant to Executive Order 13582 (targeting the Syrian government and its supporters).  The designations are part of the Trump Administration’s response to the April 4, 2017 chemical weapons … Continue Reading

Trump Administration Considers National Security Implications of Steel Imports

On April 19, the Trump administration took action under a rarely-used provision of the Trade Expansion Act of 1962, allowing the United States to impose tariffs if it determines that certain imports pose a national security threat.  Acting under section 232 of the Trade Expansion Act, the Department of Commerce announced the start of an … Continue Reading

New Iran Sanctions Bills Backed by Bipartisan Group of Key Legislators

On March 23, 2017, members of Congress introduced two new bills aimed at increasing non-nuclear sanctions against Iran. While several Iran sanctions bills have been introduced since the start of the year, these newly introduced bills are particularly notable due to their bipartisan support from an influential group of legislators. The bills represent legislative compromises … Continue Reading

Banks to Push for Reform to Anti-Money Laundering Rules

Financial institutions long have complained that current anti-money laundering (AML) regulations are costly and ill-suited to prevent crime and terrorism. According to one study, the cost of compliance with AML rules approaches $8 billion. The rise in compliance costs has coincided with a sharp increase in both the number and amount of penalties assessed by … Continue Reading

CFIUS History Redux: President Obama Blocks Chinese Purchase of Aixtron, Inc.

On Friday, December 2 – for just the third time since the creation of the Committee on Foreign Investment in the United States (“CFIUS”) – the President acted on a recommendation by CFIUS to block a foreign investment. President Obama issued an Executive Order blocking the proposed acquisition of Aixtron, Inc., a California-based U.S. subsidiary … Continue Reading

Dramatic Rise in FinCEN Enforcement

On October 3rd, the Financial Crimes Enforcement Network (FinCEN) assessed a $12 million penalty against the sports betting company CG Technology. Like something out of a bad TV crime drama, CG executives were involved with an illegal gambling operation dubbed the “Jersey Boys.”  CG failed to implement an anti-money laundering (AML) compliance system and to … Continue Reading
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