On April 18, 2023, Department of Commerce Assistant Secretary for Export Enforcement Matthew Axelrod issued a memorandum (Memorandum) that, while primarily focused on enforcement of export control restrictions, offered some

Continue Reading Expansive New Bank Secrecy Act, Sanctions Whistleblower Program: Department of Commerce Insights

On Dec. 15, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking implementing the provisions of the Corporate Transparency Act that

Continue Reading FinCEN Proposes Rule on Access to Beneficial Ownership Information

On Jan. 1, 2021, the U.S. Senate joined the House in voting to override President Trump’s veto of the National Defense Authorization Act of 2021 (NDAA), which includes several new
Continue Reading Implications for Art Dealers in Anti-Money Laundering Provisions of the National Defense Authorization Act of 2021