On April 8, 2026, the US Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) issued a joint proposed rule (“Proposed Rule”) to implement provisions of the Guiding and Establishing National Innovation for US Stablecoins Act (“GENIUS Act”). The Proposed Rule implements the GENIUS Act’s anti-money laundering (“AML”) and sanctions compliance program requirements and encourages innovation in payment stablecoins while providing a regulatory regime to mitigate…
On February 13, 2026, the US Treasury Department’s (“Treasury”) Financial Crimes Enforcement Network announced the launch of a new dedicated webpage for the confidential submission of whistleblower tips on fraud, money laundering, and sanctions violations. Based on the press release, The new initiative follows President Trump’s recent efforts to combat the government benefits fraud schemes in Minnesota. Treasury has encouraged whistleblowers to submit tips as soon as possible and to include specific, well-documented information to…
On January 29, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued new General License No. 46 (“GL 46”) authorizing transactions related to the exportation/reexportation of Venezuelan oil prohibited under the Venezuela Sanctions Regulations, 31 C.F.R. Part 591. Our blog posts about recent developments under US sanctions targeting Venezuela can be found here, here, here, and here. Subject to certain conditions, GL 46 authorizes all transactions involving the Government of Venezuela…
On November 10, 2025, the US Department of the Treasury, US Department of State, and US Department of Commerce issued a Tri-Seal Advisory (see here) summarizing the current scope of US sanctions and export controls relief measures applicable to Syria. The document serves as a consolidated reference point for the actions taken so far to relax US sanctions and export controls for Syria, including those aimed at facilitating humanitarian assistance and early recovery efforts. The…