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Terence Gilroy (US)

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On July 27, 2026, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a statement (here) of enforcement policy committing not to take supervisory or enforcement action against US financial institutions under the Bank Secrecy Act (“BSA”) in connection with the provision of authorized financial services provided in Venezuela. The statement was issued in consultation with the Internal Revenue Service and the staffs of the Board of Governors of the Federal Reserve…

On July 20, 2026, the US State Department published Public Notice 13072 imposing additional sanctions on Sudan under Section 307(b) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “Act”). The action follows the State Department’s April 24, 2025, determination under Section 306(a) of the Act, that the Government of Sudan used chemical weapons in violation of international law. Section 307(b) of the Act calls for additional sanctions unless the…

On June 23, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published a joint statement reflecting on their latest Enhanced Partnership exchange and issued a new joint guidance document that provides a comparative overview of the US and UK sanctions regimes. The joint statement and guidance follow a January 2026 in-person meeting between OFSI and OFAC. The statement and accompanying guidance…

On June 8, 2026, the US Department of Defense (“DoD”) published an update to its list of “Chinese military companies” (“CMCs”) operating directly or indirectly in the United States (the “1260H List”), pursuant to Section 1260H of the National Defense Authorization Act for Fiscal Year 2021 (the “NDAA 2021”). The updated list is available here. The DoD press release states that this update is part of the US government’s continuing effort to highlight and counter…