The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for 38 apparent violations of the Ukraine/Russia-Related Sanctions Regulations, which occurred between December 2016 and May 2020. State Street is a global financial services and bank holding company headquartered in Boston, and is...

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control provisions. This updated guidance provides clarity regarding time-bars for enforcement and includes additional information about OFAC’s planned extension of record-keeping requirements. On April 24, 2024, President Biden signed into law the 21st Century Peace...

On June 17, 2024, the U.S. Commodity Futures Trading Commission (CFTC) announced that trading giant Trafigura had agreed to pay a $55 million fine to settle charges of fraud and manipulation. The conduct at issue allegedly took place between 2014 and 2020, and included offenses such as trading on non-public information, benchmark manipulation, and impeding whistleblower communications. The high-flying commodities trading industry, through which an...

Regulators with the Federal Reserve and the Office of the Comptroller of the Currency (“OCC”) have fined JP Morgan Chase & Co. a combined total of $348.2 million over the bank’s failure to monitor client trading activities between 2014 and 2023. The enforcement action is a testament to regulators’ emphasis on the importance of sound market conduct risk controls, to which diligent record-keeping remains paramount....

Following an 8 week trial, a federal jury in Brooklyn has convicted Javier Aguilar on charges relating to the former Vitol trader’s violations of the Foreign Corrupt Practices Act. He faces up to 30 years in prison. Aguilar bribed officials in Mexico and Ecuador to obtain contracts from their state-owned oil companies. He was also convicted of using a complex money laundering scheme to avoid...

The Treasury Department’s Office of the Comptroller of the Currency (“OCC”) has taken action against the former General Counsel of Michigan-based Sterling Bank and Trust in the agency’s latest action against an individual corporate officer for failure to maintain an adequate Bank Secrecy Act (“BSA”) compliance program. Between 2012 and 2023, Colleen Kimmel was employed in various compliance-related capacities at Sterling Bank, including as General...

In a significant development, the European Union (EU) is set to implement the most comprehensive suite of regulations seen to date governing the use of artificial intelligence (“AI”) technology. The proposed regulatory overhaul aims to address a wide range of concerns surrounding AI, including ethical considerations, accountability, and potential risks to individuals and society writ large. The forthcoming “AI Act”––the final text of which was...