Ms. Mosman is an associate in Davis Polk's Financial Institutions Group and the economic sanctions and national security practice. [Full Bio]

On August 6, 2018, President Trump issued Executive Order (“E.O.“) 13846,  further implementing his May 8, 2018 decision to terminate the United States’ participation in the Joint Comprehensive Plan of Action with Iran (“JCPOA”). The following day, as certain re-imposed sanctions took effect, the President … Read More

On June 27, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced amendments to the Iranian Transactions and Sanctions Regulations (“ITSR”), 31 C.F.R. part 560, and published updated answers to frequently asked questions (“FAQs”) to further implement President Trump’s May 8, … Read More

The banking sector should pay close attention to the recent bipartisan bill supporting marijuana legal reform (the “Strengthening the Tenth Amendment Through Entrusting States Act” or the “STATES Act”) given the increasing difficulty current law creates even for those banks that are deliberately avoiding the cannabis sector.  Post mid-term elections, … Read More

The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has recently issued several new or amended Ukraine-/Russia-related General Licenses (“GLs”) and corresponding guidance related to the ongoing maintenance or wind down of certain activities involving GAZ Group and other blocked persons, and divestment of … Read More

On May 11, 2018, the customer due diligence rule, 31 C.F.R. § 1010.230 (the “CDD Rule”), issued by the Financial Crimes Enforcement Network (“FinCEN“) became applicable two years after it was issued.  The CDD Rule added a new requirement for covered financial institutions to identify, … Read More

On May 8, 2018, President Trump announced that he was terminating the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”) with Iran and issued a National Security Presidential Memorandum (“NSPM”) directing his administration to immediately begin the process of fully re-imposing sanctions that … Read More

On May 1, 2018, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two amended Ukraine/Russia related General Licenses (“GLs”): GL 12B, “Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts” and GL 13A, “Authorizing Certain … Read More

Citing the Russian government’s “range of malign activities around the globe,” on April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned seven Russian oligarchs and 12 companies they own or control, 17 senior Russian government officials, and a state-owned … Read More

The Trump Administration has officially banned U.S. transactions in Venezuela’s controversial “petro” digital currency.  On March 19, 2018, the Trump Administration issued a new Executive Order, “Taking Additional Steps to Address the Situation in Venezuela” (the “Digital Currency E.O”), which prohibits U.S. persons and others subject to … Read More

For the first time in 30 years, Congress may expand the jurisdiction of the Committee on Foreign Investment in the United States (“CFIUS”).  In testimony before the Senate Banking Committee on January 25, 2017, three Administration officials expressed support for the Foreign Investment Risk Review Modernization Act of Read More