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

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
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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
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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
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In response to feedback from financial institutions, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Ruling granting exceptive relief (the Ruling) on September 7, 2018 to covered financial institutions from certain obligations under its beneficial ownership regulation, 31 C.F.R. § 1010.230 (the
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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
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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,
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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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