Our insights

Global Investigations & Compliance Review

FinCEN and Banking Agencies Propose Customer Identification Program Rule for Stablecoin Issuers

Introduction On June 18, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), together with the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration (collectively, the “Agencies”) issued a joint notice of proposed...... Continue Reading

June 2026 | Blog

Publication

The 1 May 2026 Executive Order on Cuba: A New Era for US Sanctions on Cuba

May 2026 | Americas

Global Investigations & Compliance Review

U.S. Sanctions Review: A Recap of OFAC’s 2025 Enforcement Actions and a Look Ahead

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued four enforcement actions during the first half of this year, two in January under former President Biden and two in June under President Trump.  These actions, described below, underscore the ongoing relevance of sanctions compliance programs in the Trump era.  2025...... Continue Reading

July 2025 | Blog

Global Investigations & Compliance Review

DOJ Sets New Focus and Priorities in Digital Assets Enforcement

On April 7, 2025, U.S. Deputy Attorney General Todd Blanche issued a memorandum titled “Ending Regulation by Prosecution” (the “Memorandum”), which set out clear and direct enforcement priorities for the U.S. Department of Justice (“DOJ”) relating to digital assets. The Memorandum clarifies that DOJ is not a digital assets regulator and that it will not...... Continue Reading

April 2025 | Blog

Global Investigations & Compliance Review

OFAC Issues Additional Sanctions Guidance for the Maritime Shipping Industry

Failure to comply with the complex web of US sanctions laws and regulations carries significant risks both in terms of exposure to civil fines and penalties and reputational harm. To help maritime sector stakeholders navigate these regulations, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) has published scenario-based sanctions compliance guidance on...… Continue Reading The post OFAC Issues Additional Sanctions Guidance for the Maritime Shipping Industry appeared first on Global Investigations & Compliance Review.

November 2024 | Blog

Publication

OFAC Issues Additional Sanctions Guidance for the Maritime Shipping Industry

November 2024 | Americas

Global Investigations & Compliance Review

FinCEN Issues Investment Adviser and Real Estate Rules

On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued two final rules to counter financial crime and safeguard national security: one broadening the definition of “financial institution” to include certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) under the Bank Secrecy Act (“BSA”), and one mandating...… Continue Reading The post FinCEN Issues Investment Adviser and Real Estate Rules appeared first on Global Investigations & Compliance Review.

October 2024 | Blog

Global Investigations & Compliance Review

OFAC Guidance on the Statute of Limitations Extension

The President’s signing of the 21st Century Peace through Strength Act (the “Act”)[1] on April 24, 2024 marked one of the most significant expansions of the sanctions enforcement authority of the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). For many decades OFAC’s civil enforcement actions have been limited to five years...… Continue Reading The post OFAC Guidance on the Statute of Limitations Extension appeared first on Global Investigations & Compliance Review.

July 2024 | Blog

Global Investigations & Compliance Review

Increasing US Enforcement Action for Sanctions Violations by Crypto Exchanges Likely to Have Ripple Effect in UK and Europe

The investigation and enforcement of potential sanctions violations by crypto exchanges is an area of focus in the US at present.  The US Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) recent settlement with Kraken, a global virtual currency exchange, is the most recent OFAC case demonstrating the risks for virtual currency platforms...… Continue Reading The post Increasing US Enforcement Action for Sanctions Violations by Crypto Exchanges Likely to Have Ripple Effect in UK and Europe appeared first on Global Investigations & Compliance Review.

December 2022 | Blog