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  • U.S. Government Revokes Certain Sanctions on Sudan Following Review Period of Sudanese Policies and Actions

    Financial Crimes

    On October 6, the U.S. Government announced, effective October 12, the revocation of certain economic sanctions against Sudan and the Government of Sudan (GOS) as a recognition of sustained positive actions in connection with efforts to cease hostilities, improve humanitarian access, promote regional stability, and address the threat of terrorism. As previously covered in InfoBytes, the announcement follows a joint review conducted by the Secretary of State, the Secretary of the Treasury, the Director of National Intelligence, and the Administrator of the U.S. Agency for International Development that began in January 2017 as required by Executive Order 13761 and amended by Executive Order 13804. The Secretary of State issued a contemporaneous report concluding that, despite GOS’ demonstrated improvement in the areas that led to the issuance of Executive Order 13761, there remain a range of concerns. As such, while the comprehensive sanctions program has been lifted, certain sanctions and trade restrictions remain in place. Specifically:

    • the national emergency, established in Executive Order 13067 with respect to Sudan, remains in effect;
    • U.S. sanctions related to the conflict in Darfur, pursuant to Executive Order 13400, remain in place;
    • The U.S. Government maintains the authority to designate Sudanese persons according to other relevant sanctions authorities; and
    • Sudan remains on the list of state sponsors of terrorism, which will continue to impose restrictions on certain dealings involving Sudan, including U.S. foreign assistance and restrictions on defense exports and sales.

    Following revocation of the sanctions, U.S. persons will no longer be banned from engaging in most transactions previously prohibited by the Sudanese Sanctions Regulations (31 C.F.R. Part 538).

    The U.S. Treasury Department’s Office of Foreign Assets Control also released updated FAQs to answer questions related to the revocation, along with a new general license that authorizes certain transactions.

    Financial Crimes Sanctions OFAC Department of Treasury Department of State Executive Order

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  • OFAC Imposes Additional North Korean Sanctions; Senate Banking Committee Hearing Discusses Multi-Department Efforts

    Financial Crimes

    On September 26, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced it was imposing sanctions on an additional eight North Korean banks and 26 individuals connected to North Korean financial networks across the globe. The individuals sanctioned are North Korean nationals who represent North Korean banks operating in China, Russia, Libya, and the UAE, and have been designated “in response to North Korea’s ongoing development of weapons of mass destruction and continued violations of United Nations Security Council Resolutions.” OFAC’s action complements the United Nations Security Council’s resolution UNSCR 2375, adopted September 11, 2017. As a result, property or interests in property of the designated persons within U.S. jurisdictions are blocked.

    These actions closely follow President Trump’s recent issuance of sanctions targeting individuals, companies, and financial institutions that finance or facilitate trade with North Korea. (See previous InfoBytes coverage here.)

    Additionally, the Senate Committee on Banking, Housing, and Urban Affairs (Committee) held an open session hearing on September 28 entitled “Evaluating Sanction Enforcement and Policy Options on North Korea: Administration Perspectives.” Committee Chairman Mike Crapo (R-Idaho) opened the hearing to stress that “[m]any Members of Congress, including on this committee, have a keen interest in knowing more about how and when enforcement of these new measures will occur, wondering if last week’s executive order and earlier UN sanctions will be sufficient to achieve U.S. policy goals.” Sen. Crapo also mentioned the Committee’s legislative efforts to “maximize pressure against North Korea.”

    The September 28 hearing—a video of which can be accessed here—included testimony from the following witnesses concerning North Korea’s nuclear and ballistic missile program and the need to curtail the country’s access to revenue, trade, and financial systems.

    • The Honorable Sigal Madelker, Under Secretary for Terrorism and Financial Crimes, U.S. Department of the Treasury (testimony)
    • Ms. Susan A. Thornton, Acting Assistant Secretary, Bureau of East Asian and Pacific Affairs, U.S. Department of State (testimony)

    Financial Crimes Sanctions OFAC Department of Treasury Senate Banking Committee Department of State

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  • GAO Issues Report on Combating Narcotics-Related Money Laundering in the Western Hemisphere

    Financial Crimes

    On September 7, the U.S. Government Accountability Office (GAO) issued a report, Anti-Money Laundering: U.S. Efforts to Combat Narcotics-Related Money Laundering in the Western Hemisphere, detailing activities by the Treasury and State Departments to combat these illicit activities. In conducting the study, GAO reviewed laws, regulations, and budget data, and also conducted interviews with experts and U.S. officials, in order to examine anti-money laundering activities over the period of fiscal years 2011 through 2015. GAO also made site visits to Colombia, Mexico, and Panama, identified as “jurisdictions of primary concern for money laundering” by the State Department. Among other things, the report noted that “State and Treasury allocated about $63 million to support AML-related capacity-building and technical assistance” to fund training and equipment for financial intelligence units employed to detect illicit financial transactions in these countries. The report further provides that many entities are required to report suspicious activities to the Treasury’s Financial Crimes Enforcement Network, which was established to collect, analyze, and disseminate “financial intelligence information to combat money laundering.”

    Financial Crimes Anti-Money Laundering GAO Bank Secrecy Act Department of Treasury Department of State FinCEN

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  • OFAC Authorizes Belarus-Related General License

    Federal Issues

    On October 18, OFAC granted General License No. 2B renewing the authorization regarding nine Belarusian entities to enter into transactions otherwise prohibited by Executive Order 13405. General License No. 2B replaces and supersedes in its entirety General License No. 2A, which was set to expire later this month, and authorizes transactions with any entities that are owned 50 percent or more by the nine named entities. All property and interests in property of these entities, if blocked, remain blocked. U.S. persons must report authorized transactions or any series of transactions exceeding $50,000 to the U.S. Department of State no later than 30 days after execution. The authorization expires on April 30, 2017, unless otherwise extended or revoked.

    Federal Issues International OFAC Department of State

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