FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security Urge Increased Vigilance for Potential Russian and Belarusian Export Control Evasion Attempts

The Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS)1 are issuing a joint alert2 urging financial institutions3 to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with the Russian Federation’s (Russia) further invasion of Ukraine. This joint alert … Read more

The Continued Use Cryptocurrency Exchanges and Tools to Lessen the Strength of U.S. Sanctions

The Treasury Department continues to investigate sanctions violations by crypto exchange companies in whether their crypto exchange allows users in sanctioned countries to buy and sell digital tokens. For example, The Treasury Department’s Office of Foreign Assets Control has been investigating Kraken since 2019 as reported by NY Times. It appears that Kraken would be … Read more

ERiSA Plan Sponsors Need to Verify That All Service Providers and Vendors Meet DOL Cybersecurity Guidelines

The Department of Labor’s (DOL) release of cybersecurity best practices for plans covered by the Employee Retirement Income Security Act (ERISA) makes it clear that plan sponsors, service providers, and participants share responsibility for protecting plan accounts.  The guidance, which includes tips for hiring service providers, cybersecurity program best practices, and online security tips, provides … Read more

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