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

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,
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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
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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,
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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
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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
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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
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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
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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
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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
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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
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