Ms. McGuinness is counsel in Davis Polk’s Financial Institutions Group and the economic sanctions and national security practice. [Full Bio]

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

The past few days have seen several interesting developments in the law and regulation of digital tokens.  Each action reflects an intense focus by U.S. regulators to clarify the treatment of digital tokens, from those issued by startups in initial coin offerings (ICOs) to the more “traditional” cryptocurrencies … 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

Following on last week’s hearing in which it heard testimony from private sector representatives, the Senate Banking Committee continued its consideration of possible reforms to the U.S. anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) framework with a January 17, 2018 hearing in which … Read More

Despite his long-held stance that it is one of the worst deals ever, today President Trump again executed the necessary waivers to continue the United States’ nuclear sanctions relief to Iran in compliance with the Joint Comprehensive Plan of Action (the “JCPOA”).  The President made clear in a statement, … Read More

In its first hearing of the year, the Senate Committee on Banking, Housing, and Urban Affairs expressed support for potential reforms to the U.S. anti-money laundering (“AML”) and countering the financing of terrorism (“CTF”) framework.  The hearing focused on the relationships among financial institutions, regulators, and … Read More

On October 13, 2017, President Trump announced that he would not make a quarterly certification required by the Iran Nuclear Agreement Review Act (“INARA”) because he was unable to certify that the provision of sanctions relief to Iran under the Joint Comprehensive Plan of Action (“JCPOA”) is appropriate and proportionate … Read More

On September 21, 2017, President Trump issued a new Executive Order (“E.O.”), “Imposing Additional Sanctions With Respect to North Korea.”  According to Treasury Secretary Mnuchin, the new E.O. expands the “Treasury’s authorities to target those who enable [the North Korean] regime’s economic activity.”  In particular, Secretary Mnuchin noted that … Read More

The State Department confirmed during a September 14, 2017 press briefing that the Trump administration has executed a necessary waiver to continue the United States’ nuclear sanctions relief to Iran in compliance with the Joint Comprehensive Plan of Action (the “JCPOA”).  Throughout the briefing, however, the State Department focused more … Read More