On October 1, 2020, the US Department of the Treasury (“Treasury”) issued a pair of advisories to alert companies about risks associated with ransomware scams and attacks. Ransomware is malicious software designed to block access to a computer system or data, often by encrypting data or programs on information technology systems to extort ransom payments from victims in exchange for decrypting the information and restoring victims’ access to their systems or data. The advisories suggest that…
On October 25, 2019, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule identifying Iran as a jurisdiction of primary money laundering concern (“Final Rule”) under Section 311 of the USA PATRIOT ACT, seeking to further isolate Iran from the global financial system. Concurrently, the US Treasury and State Departments announced a new humanitarian mechanism to ensure that funds associated with permissible trade in support of the Iranian people are not diverted by the Iranian regime to develop ballistic missiles, support terrorism, or finance other malign activities. These measures build upon the US Treasury Department’s Office of Foreign Assets Control’s (“OFAC”) additional sanctions against the Central Bank of Iran discussed in our prior blog post here.
On October 16, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated certain Iranian entities and banks as Specially Designated Nationals (“SDNs”) pursuant to Executive Order (“EO”) 13224, which targets terrorists and those providing support to terrorism. A full list of those entities designated as part of this action is available here. US Persons (i.e., entities organized under US laws and their non-US branches; parties physically located in the United States; US citizens and permanent resident aliens wherever located or employed) are prohibited from dealing directly or indirectly with SDNs. Under the Iranian Transactions and Sanctions Regulations (“ITSR”), non-US entities owned or controlled by US Persons are also prohibited from dealing with SDNs that are located or based in Iran (regardless of their reason for designation) or owned or controlled by the Government of Iran (regardless of where they are located).
On June 29, 2017, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued for public inspection a notice of proposed rulemaking (the “Proposed Rule”) that would restrict a Chinese commercial bank’s access to the US financial system based on a finding that the bank was involved in money laundering activities involving North Korea. This action coincided with designations by the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) of one entity and two individuals with alleged ties to North Korea.