White House Issues Open Letter to Private Businesses Regarding the Threat of Ransomware | Foley & Lardner LLP jdsupra.com - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from jdsupra.com Daily Mail and Mail on Sunday newspapers.
Matthieu Crozet, Julian Hinz, Amrei Stammann, Joschka Wanner
Politics affects the banking sector in many ways (e.g. Calomiris and Huber 2014). For example, governments in many countries direct commercial bank lending to specific sectors and/or stimulate lending to small and medium-sized enterprises (e.g. Brown and Dinc 2005). And during the recent COVID-19 pandemic, many governments created emergency loan guarantee schemes that were covering and spurring their banks lending. In this column, we turn to another recent and striking episode of political impact, namely, the global financial sanctions on Russian banks with close ties to their domestic government that commenced in 2014 and were sequentially imposed on various banks during a five-year period. In general, economic sanctions become increasingly popular from 2010s, being mostly driven by the US to restrain politically unfavourable regimes (Felbermayr et al. 2021). While their effects at the firm level are well studied (Croz
The Office of the Chief Accountant of the SEC's Division of Investment Management periodically issues "Dear Chief Financial Officer" letters to help registered investment companies.
OFAC “may” include virtual currency wallet addresses on SDN List
The Office of Foreign Asset Control of the Department of Treasury (OFAC) forecasted that it “may include as identifiers on the SDN List specific digital currency addresses associated with blocked persons.”
SDN stands for “Specifically Designated Nationals and Blocked Persons” and the “SDN List” is a list of persons and entities, designated by OFAC, whose “assets are blocked and U.S. persons are generally prohibited from doing business with them.” Persons and entities on the SDN List are commonly referred to as sanctioned persons or entities.
OFAC recently posted “Questions on Virtual Currency,” a section of their frequently asked questions, which indicates that OFAC may be adding virtual currency wallet addresses to the SDN List. According to OFAC, when it comes to OFAC compliance the “obligations are the same” whether operating in virtual currency or fiat. Persons or entities “are res
1. Recent Enforcement: Even Companies That Invest in Compliance Pay Penalties
Since our April enforcement roundup, the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) in the Department of Commerce have issued several important penalty announcements. These enforcement actions demonstrate that even multinational companies that invest in compliance can run into problems without a continued commitment to monitoring and updating their programs.
Global software company SAP SE paid a total of $8 million in a combined global resolution with the Department of Justice (DOJ), Commerce, and Treasury for illegal exports, and it also disgorged $5.14 million in profits. Between December 2009 and September 2019, the company exported its software, upgrades, and patches more than 20,000 times to end users in sanctioned countries, including Iran, without a license. As part of the settlement, SAP must perform three internal audits of its export compliance program