On June 28, 2022, the Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a rare Joint Alert focused on the
Continue Reading FinCEN and BIS Warn Financial Institutions About Potential Evasion of Russian and Belarusian Export Controls
Miranda R. Carnes
Miranda R. Carnes focuses her practice on navigating cross-border disputes and compliance, including international litigation and arbitration, International Trade regulation, and public international law. In International Trade matters, she counsels clients on U.S. export controls and economic sanctions, antidumping and countervailing duty investigations, and customs matters. She advises clients on a range of economic sanctions and export controls issues, including those arising under sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the International Traffic in Arms Regulations (ITAR), and the Export Administration Regulations (EAR).
In international litigation matters, Miranda represents clients in U.S. proceedings to obtain discovery for use in foreign litigations and to enforce (or defend against the enforcement of) foreign judgments and arbitration awards. She also represents clients before OFAC and the International Criminal Police Organization (INTERPOL) in connection with cross-border criminal investigations. These proceedings generally have a Latin America focus.
Finally, Miranda helps advise governments on matters raising issues of public international law, including international humanitarian law, the law of the sea, and obligations that arise from multilateral and bilateral treaties.
CFPB Circular 2022-03: Complex Lending Algorithms Cannot Excuse Failure to Provide Specific, Principal Reasons for an Adverse Credit Determination
On May 26, the Consumer Financial Protection Bureau (the Bureau or CFPB) issued its third Circular, emphasizing that creditors must adhere to the Equal Credit Opportunity Act (ECOA) and…
Continue Reading CFPB Circular 2022-03: Complex Lending Algorithms Cannot Excuse Failure to Provide Specific, Principal Reasons for an Adverse Credit Determination