Jack Hayes

Jack Hayes

Jack Hayes has extensive experience providing clients with advice and assistance under ITAR and EAR, as well as US economic sanctions and anti-boycott regulations. Jack frequently handles complex export control matters, including voluntary disclosures, internal investigations of apparent export control violations, pre-closing and post-closing acquisition export compliance due diligence, export control audits, and assessments of compliance obligations and risks in accordance with relevant international trade regulations. He also provides guidance on brokering requirements and reporting obligations for certain fees, commissions, and political contributions related to sales of defense articles and defense services, prepares export and reexport license and agreement applications for submission, undertakes commodity jurisdiction and export classification analyses of items and services under the ITAR and EAR, drafts registration material change notifications, and develops compliance policies, programs, and training materials.

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AML CDD Rule for Certain U.S. Financial Institutions Effective Today

The FinCEN Customer Due Diligence Requirements for Financial Institutions, known as the CDD Rule or the “Fifth Pillar,” becomes effective today for certain covered U.S. Financial Institutions.  This CDD Rule, which amends U.S. Bank Secrecy Act regulations, seeks to improve financial transparency and prevent money laundering/terrorist financing.  The CDD Rule applies to covered U.S. financial … Continue Reading

Texas-Based U.S. Gold Refinery Pleads Guilty for Failing to Maintain an Adequate Anti-Money Laundering Program and Agrees to Forfeit $15M, Continuing Trend of Criminal Enforcement Actions and Prosecutions for Compliance Failures

A series of recent federal enforcement actions targeting weaknesses in Bank Secrecy Act/anti-money laundering (BSA/AML) compliance programs continued on March 16, when U.S. Gold refinery Elemetal LLC, based in Dallas, Texas, pled guilty in U.S. District Court for the Southern District of Florida to a single-count information charging failure to maintain an adequate BSA/AML program. … Continue Reading

Who’s Your Correspondent? FinCEN Penalizes Texas-Based Bank for Bank Secrecy Act Violations

On November, 1, 2017, the US Department of the Treasury, Financial Crimes Enforcement Network (FinCEN), announced that Lone Star National Bank (Lone Star), operating in Texas, entered into a civil money penalty consent for alleged willful violations of the Bank Secrecy Act (BSA) and 31 C.F.R. Chapter X regulations involving inadequate anti-money laundering (AML) compliance … Continue Reading

OFAC Reaches Settlement Agreement with Richemont North America

On September 26, 2017, the US Office of Foreign Assets Control (OFAC) published information about a civil enforcement action against Richemont North America, d.b.a. Cartier, headquartered in New York.  Richemont agreed to settle charges and pay approximately $334,800 for allegedly selling jewelry to a Specially Designated National and Blocked Person designated under the Foreign Narcotics … Continue Reading

Power of the Pen: Did Chairman Corker’s Letter End US Arms Sales to Saudi Arabia?

On June 26, Senator Corker, Chairman of the Senate Foreign Relations Committee (SFRC), informed Secretary Tillerson that, in light of the current diplomatic stalemate between Saudi Arabia, the United Arab Emirates, and Qatar, the SFRC would not “provide any further clearances during the informal review period on sales of lethal military equipment” to the six … 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

DDTC and BIS Publish Long-Awaited Final Rules for Category XII: Night Vision and Cameras

On October 12, 2016, the State Department’s Directorate of Defense Trade Controls (DDTC) and the Commerce Department’s Bureau of Industry and Security (BIS) published companion final rules to amend Category XII of the United States Munitions List (USML) and move some less sensitive items to the Commerce Control List (CCL).  The final rules will become … Continue Reading

UN Tightens the Screws on North Korea with Additional Trade and Banking Sanctions

On November 30, 2016, UN Security Council Resolution (UNSCR) 2321 was adopted, pushing the limits on how far international economic sanctions can go in isolating the North Korean regime without entirely collapsing the country’s economy.  The resolution also lays out a handful of additional legal restrictions that will be pertinent for US and international stakeholders … Continue Reading

Treasury’s Cold Comfort Message Regarding Correspondent Banking and AML/Sanctions

For several years, banks have been bludgeoned with anti-money laundering (AML) and sanctions penalties. These twin hammers, increasingly wielded simultaneously and synergistically by regulators and prosecutors, have produced multi-billion dollar penalties.  The Treasury Department now has released a message seemingly intended to provide some comfort to the bruised and wary banking community.  But that comfort … Continue Reading

Customer Due Diligence Guidance by FinCEN for Certain Financial Institutions

On July 19, 2016, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued Frequently Asked Questions to clarify the scope of its rule, “Customer Due Diligence (CDD) Requirements for Financial Institutions.”  Steptoe’s International Compliance Blog covered the rule in May. This rule took effect on July 11, 2016, but does not require … Continue Reading

Compliance Issues Regarding the Syrian Conflict

In light of recent events related to Syria, it is possible that companies will be approached by entities seeking to arm or otherwise assist the Syrian opposition or the Kurdish Peshmerga.  We remind companies subject to the ITAR that there are significant compliance issues associated with such transfers, whether directly to the opposition or the … Continue Reading

Jack Hayes Featured on “Food Crimes” Documentary Series

Steptoe’s Jack Hayes is featured on Food Crimes, a new investigative documentary web series in partnership with Food Republic, to discuss the economic sanctions of the rarefied world of saffron.  The episode, titled “Mad About Saffron,” investigates the tangled history and contemporary complexities of the spice. Mr. Hayes says: “The idea is we’ll deny business … Continue Reading

Implications for the Insurance, Reinsurance, and Brokerage Industry Under the JCPOA

Steptoe’s Guy Soussan and Jack Hayes recently published an article in Insurance Day about the implications for the insurance, reinsurance, and brokerage industry under the Joint Comprehensive Plan of Action (JCPOA) related to Iran.  There are five key points: Virtually all EU insurance-related sanctions would be removed. Some, but not all, US insurance-related sanctions would … Continue Reading
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