Do State Regulators Like the NYDFS Have Authority to Enforce OFAC Sanctions?

Robust Enforcement of OFAC Sanctions by Federal Authorities In recent years the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and other federal authorities have robustly enforced OFAC-administered sanctions against banks, particularly U.S. branches of foreign banks. Notable for their number, successiveness, and monetary penalty amounts imposed—often for U.S. sanctions and related

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Hdeel Abdelhady Discussed the NYDFS Habib Bank Enforcement Action

MassPoint's Founder and Principal, Hdeel Abdelhady, discussed the legal significance and potential commercial implications of the NYDFS' enforcement action against Habib Bank at a time of correspondent banking derisking. Ms. Abdelhady stated that: "at any time, the loss a New York banking license and direct access to the U.S. financial system would be devastating, but the

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House Bill Would Establish National Strategy for Combating Terrorism Financing

On July 20, 2017, Representative Ted Budd (R-NC) introduced in the House of Representatives H.R. 3321, the “National Strategy for Combating Terrorist, Underground, and Other Illicit Financing Act.” The purpose of H.R. 3321 is to “require the establishment of a national strategy for combating the financing of terrorism and related financial crimes, and for other purposes.” As summarized by

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World Bank Accountability Act of 2017

World Bank Accountability Act of 2017 Would Condition Certain U.S. Appropriations on World Bank’s Anti-Corruption and Counter-Violent Extremism Performance and Authorize Trump Administration’s Request to Reduce Funding to IDA  On July 25, 2017, the House Financial Services Committee will meet to markup H.R. 3326, the “World Bank Accountability Act of 2017.” H.R. 3326 was introduced

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Congressional Hearing: Managing Terrorism Financing Risk in Remittances and Money Transfers

Congressional Subcommittee to Hold Hearing on Terrorism Financing Risk in Remittances and Money Transfers  The U.S. House of Representatives Financial Services Committee (the “FSC“) Terrorism and Illicit Finance Subcommittee will on July 18, 2017 hold a hearing entitled “Managing Terrorism Financing Risk in Remittances and Money Transfers.”  The FSC memorandum to all of its members states

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Correspondent Banking and Derisking Update

Financial Stability Board Publishes Action Plan to Address Decline in Correspondent Banking/Derisking Correspondent Banking Update |  July 4, 2017  | Author: Hdeel Abdelhady Ahead of the upcoming G20 meeting, the Financial Stability Board (FSB) published today, July 4, 2017, a progress report on efforts to address the withdrawal of correspondent banking relationships (derisking) and its action

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Maryland Banking Regulation: Commercial Bank Directors State Residency

Commercial banks in Maryland will soon have an added degree of latitude in selecting their directors. On April 18, 2017, Governor Hogan approved Maryland Senate Bill 206, Financial Institutions – Qualifications of Directors of Commercial Banks – Residency (the “Amendment”). The Amendment, which repeals and reenacts, with amendments, Section 3-403 of the Maryland Code, Financial Institutions Article,

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State-Owned Enterprises and Anti-Corruption Enforcement

Anti-Corruption Enforcement and State-Owned Enterprises: Understand Unique Risks and Incentivize Compliance State-owned enterprises (SOEs, including sovereign wealth funds) are prominent players in international business. Given their ownership, SOEs have garnered scrutiny for their lack of transparency and heightened anti-corruption and anti-money laundering risk, as have individual SOE executives and other personnel who qualify as Politically

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Dana Gas Deems its Own Sukuk Unlawful: Parsing the Dana Gas Statement

Dana Gas Declares its Own Sukuk “Unlawful:” Issues, Questions, and Observations [1]   June 18, 2017 | Author: Hdeel Abdelhady* As discussed briefly in this June 16 MassPoint blog post, Dana Gas PJSC, the Sharjah, UAE-based gas producer, has unilaterally declared “unlawful” sukuk[2] instruments issued by the company in 2013 [3] (through, as issuer, Dana Gas Sukuk

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