De-Risking in Global Financial Institutions
Previously, I have written about how the major enforcement actions against global financial institutions for Iran sanctions-related violations should not…
The Conundrum of Contesting a Kingpin Act Designation
his past Tuesday, OFAC designated two individuals and two entities pursuant to the Foreign Narcotics Kingpin Designation Act ("the Kingpin…
TFFC Omits Derisking from the 2015 National Money Laundering Risk Assessment
The 2015 National Money Laundering Risk Assessment (“NMLRA”), produced by Treasury’s Office of Terrorist Financing and Financial Crime (“TFFC”), is…
Hastert Proves Structuring Isn’t Just for Drug Dealers
While we normally focus exclusively on sanctions here at Sanction Law, it’s important to recognize sanctions and money laundering are…