Andres A. Fernandez

Treasury Designates Bank Tejarat For Its Involvement In WMD Proliferation Activities
Andres A. Fernandez,Marina Olman,Clemente L. Vázquez-Bello, January 27, 2012
The U.S. Department of Treasury (“Treasury”) recently announced (“Announcement”) the designation of Iran’s third-largest bank, Bank Tejarat, under Executive Order 13382 - Blocking Property of Weapons of Mass Destruction (“WMD”) Proliferators and Their...

OFAC Issues Regulations Relating to Transnational Criminal Organizations
Andres A. Fernandez,Marina Olman,Clemente L. Vázquez-Bello, January 23, 2012
The Office of Foreign Assets Control (“OFAC”) has recently issued the Transnational Criminal Organizations Sanctions Regulations (“TCO Regulations”) to implement Executive Order 13581 of July 24, 2011, Blocking Property of Transnational Criminal Organizations...

FinCEN Assesses Civil Money Penalty for Suspicious Activity Report Disclosure
Andres A. Fernandez,Marina Olman,Clemente L. Vázquez-Bello, December 29, 2011
On December 15, 2011, the Financial Crimes Enforcement Network (“FinCEN”) assessed a $25,000 civil money penalty against a bank employee for unlawfully revealing the existence of a Suspicious Activity Report (“SAR”) to the subject of the SAR (“CMP”). FinCEN...