• Recent Developments in BSA/AML and Sanctions: New Sanctions Targeting Persons in Venezuela and Expansion of Sanctions Addressing the Situation in Ukraine; DOJ Reaches First Criminal Settlement in “Operation Choke Point”; and FinCEN Proposes Special Measures Against an Andorran Bank Under Section 311 of the USA PATRIOT Act
  • April 6, 2015 | Authors: Nicolas Bourtin; H. Rodgin Cohen; Elizabeth T. Davy; Mitchell S. Eitel; Jared M. Fishman
  • Law Firm: Sullivan & Cromwell LLP - New York Office
  • Last week, there were several important developments in the areas of U.S. Bank Secrecy Act/anti-money laundering (“BSA/AML”) and U.S. economic sanctions. On Monday, March 9, 2015, the President issued Executive Order 13692, implementing, for the first time, sanctions under the Venezuela Defense of Human Rights and Civil Society Act of 2014.