Robert T. Dura

Debevoise Discusses FinCEN’s Guidance on the Customer Due Diligence Rule

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On April 3, 2018, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued long-awaited frequently asked questions (“FAQs”) regarding its new customer due diligence requirements (“CDD Rule”) that become effective on May 11, 2018.1 As a reminder, on May 11, 2018, the CDD Rule will require covered financial institutions (1) to establish procedures to identify and verify the identity of the beneficial owners of legal entity customers that open new accounts unless an exception applies and (2) ensure their anti-money laundering (“AML”) compliance programs include appropriate risk-based procedures for ongoing CDD efforts, including developing customer risk profiles and periodically … Read more

Debevoise & Plimpton Discusses U.S. Guidance on New Russian Sanctions

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On Tuesday, October 31, the U.S. Departments of State and Treasury issued new guidance the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) relating to sanctions against Russia. This is in addition to guidance that the State Department previously issued on CAATSA Section 231.

Amendments to Directive 4

Section 223(d) of CAATSA directed the Treasury Department to expand the scope of Directive 4 of the Sectoral Sanctions Identifications (“SSI”) List, which governs the provision of goods and services by U.S. persons to certain types of oil projects. The new restrictions are effective January 29, 2018.

Currently, the restrictions apply only to … Read more