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

On January 28, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned Petroleos de Venezuela S.A. (“PdVSA”), Venezuela’s state-owned oil company, pursuant to Executive Order (“E.O.”) 13850 for operating in the oil sector of the Venezuelan economy, following a determination by the Secretary
Continue Reading OFAC Designates PdVSA

As 2018 came to a close, U.S. financial regulators continued to pursue anti-money laundering (“AML”) enforcement actions against financial institutions, announcing monetary penalties against and resolutions with three U.S. broker-dealers.  The Financial Crimes Enforcement Network (“FinCEN”), the Securities and Exchange Commission (“SEC”) and the
Continue Reading U.S. Regulators Announce BSA/AML Enforcement Actions Against U.S. Broker-Dealers

On December 19, 2018, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced its plan to lift sanctions on three Russian entities for agreeing to distance their businesses from a prominent oligarch.  Specifically, OFAC informed Congress of its intention to terminate sanctions on entities previously designated for
Continue Reading OFAC Announces Intent to Delist Rusal and Other Entities Owned by Sanctioned Oligarch Deripaska

On December 3, 2018, a U.S. government working group aimed at improving the effectiveness and efficiency of the BSA/AML regime issued a second joint statement, which focuses on innovative industry approaches to BSA/AML compliance.  This follows the working group’s first joint statement last month, which focused on BSA/AML resource sharing
Continue Reading FinCEN and Banking Regulators Issue Joint Statement on Innovation in BSA/AML Compliance

On November 19, 2018, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued an advance notice of proposed rulemaking (“ANPRM”) seeking public comment on “criteria for identifying emerging technologies that are essential to U.S. national security.”[1]  The ANPRM was issued pursuant to the Export Control Reform
Continue Reading First Step Toward Defining “Emerging Technology” Under Export Control Reform Act

On November 19, 2018, a group of five U.S. federal and state prosecutors and regulators[1] announced that they had reached settlements with Société Générale (“SocGen”) under which SocGen will pay penalties totaling $1.34 billion in relation to violations of U.S. economic sanctions concerning Iran, Cuba, Sudan and
Continue Reading U.S. Prosecutors and Regulators Impose Second Largest Penalty Ever Levied Against a Financial Institution for Violations of U.S. Economic Sanctions

On October 11, 2018, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a lengthy “Advisory on the Iranian Regime’s Illicit and Malign Activities and Attempts to Exploit the Financial System,” (the “Iran Advisory”), which provides examples and typologies of the Iranian regime’s exploitation
Continue Reading As Sanctions “Snap-Back” Approaches, FinCEN Advisory Emphasizes Risks to the U.S. and International Financial Systems Posed by Iran

On October 5, 2018, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had entered into an approximately $5.3 million civil monetary settlement with JPMorgan Chase Bank, N.A. (“JPMC”) for apparent violations of the Cuban Assets Control Regulations, 31 C.F.R. Part 515, the
Continue Reading OFAC Enforcement Action Highlights Risk of Indirect Sanctions Violations, Importance of Acting on “Red Flags”

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and the federal banking regulators have taken a small step towards improving the BSA/AML compliance framework for depository institutions.  These agencies issued a Joint Statement on Banks and Credit Unions Sharing Resources to Improve Efficiency and Effectiveness of Bank Secrecy Act Compliance
Continue Reading One Small Step for AML: Federal Banking Regulators Issue Joint Statement on BSA/AML Resource Sharing

The past two weeks have seen a number of developments with respect to U.S. sanctions relating to Russia, as the Trump administration has (1) taken additional steps to ameliorate adverse consequences for U.S. persons of the significant sanctions actions targeting Russian oligarchs announced on April 6, 2018; (2) further implemented
Continue Reading Russia Sanctions Updates