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Andres A. Fernandez Document Search Results (17) Show: results per page Sort by:  | President’s Order Prohibits Certain Sanction-Evasive Acts with Respect to Iran and Syria
Gabriel Caballero, Andres A. Fernandez, Clemente L. Vázquez-Bello; Gunster;
Legal Alert/Article May 4, 2012, previously published on May 2, 2012 Yesterday, President Barack Obama issued an Executive Order (the “Order”) prohibiting certain transactions with and suspending entry into the U.S. of Foreign Sanctions Evaders (“FSEs”) with respect to Iran and Syria.
| | Federal Reserve Issues Cease and Desist Order
Gabriel Caballero, Andres A. Fernandez, Clemente L. Vázquez-Bello; Gunster;
Legal Alert/Article April 26, 2012, previously published on April 20, 2012 On April 2, 2012, the Board of Governors of the Federal Reserve System (“Board”) issued a Cease and Desist Order (the “Order”) and assessed a $975,000 Civil Money Penalty against Banco Espírito Santo S.A. (“BES”), Lisbon, Portugal, and its affiliate in the...
| | OCC Issues Cease and Desist Order Against Citibank
Gabriel Caballero, Andres A. Fernandez, Clemente L. Vasquez-Bello; Gunster;
Legal Alert/Article April 16, 2012, previously published on April 11, 2012 On April 5, 2012, the Office of the Comptroller of the Currency ("OCC") issued a Cease and Desist Order (the "Order") against Citibank, N.A. ("Citi"), Sioux Falls, South Dakota.
| | FinCEN Releases Electronic Form for Registration of Money Services Businesses (MSBs)
Gabriel Caballero, Andres A. Fernandez, Clemente L. Vázquez-Bello; Gunster;
Legal Alert/Article March 20, 2012, previously published on March 16, 2012 Yesterday, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice regarding the release of the new electronic Registration of Money Services Business, FinCEN Report 107. The new report will fully replace the most recent FinCEN Report 107 and facilitates registration for all...
| | FinCEN Seeks Comments on Proposed Rule on How Financial Institutions Collect Account Ownership Info
Gabriel Caballero, Andres A. Fernandez, Clemente L. Vázquez-Bello; Gunster;
Legal Alert/Article March 9, 2012, previously published on March 2, 2012 The U.S. Treasury Department, through the Financial Crimes Enforcement Network (FinCEN), has just issued an Advance Notice of Proposed Rulemaking (ANPRM) through which FinCEN solicits comments in advance of its issuance of an express rule that will require by regulation that financial institutions...
| | Increased Use of Suspicious Activity Reports in Private Litigation Raises Confidentiality Concerns
Gabriel Caballero, Andres A. Fernandez, Clemente L. Vázquez-Bello; Gunster;
Legal Alert/Article March 9, 2012, previously published on March 5, 2012 Due to its continuing concern with the confidentiality of Suspicious Activity Reports (SARs) and the prohibition from disclosing SARs, on March 2, 2012, FinCEN issued an Advisory to remind financial institutions and, in particular, the lawyers that advise them, of the requirement to maintain the...
| | Treasury Designates Bank Tejarat For Its Involvement In WMD Proliferation Activities
Andres A. Fernandez, Marina Olman, Clemente L. Vázquez-Bello; Gunster, Yoakley & Stewart, P.A.;
Legal Alert/Article January 27, 2012, previously published on January 26, 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; Gunster, Yoakley & Stewart, P.A.;
Legal Alert/Article January 23, 2012, previously published on January 19, 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; Gunster, Yoakley & Stewart, P.A.;
Legal Alert/Article December 29, 2011, previously published on December 27, 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...
| | Are S.E.C. Settlements Without Any Admission Or Denial Of The Allegations A Thing Of The Past?
Andres A. Fernandez, Marina Olman, Clemente L. Vázquez-Bello; Gunster, Yoakley & Stewart, P.A.;
Legal Alert/Article December 19, 2011, previously published on December 11, 2011 Last week, a District Judge in the Southern District of New York—the Honorable Jed S. Rakoff—refused to approve a proposed Consent Judgment in a securities fraud suit by the U.S. Securities and Exchange Commission (“S.E.C.”) against Citigroup Global Markets Inc....
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