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Financial Services Law Insights and Observations

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  • OFAC announces sanctions tied to drug trafficking

    Financial Crimes

    On November 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14059 against three individuals and nine entities for supplying certain drugs to U.S. markets through internet sales and a host of shell companies. OFAC noted that the sanctions would not have been possible without collaboration with the Drug Enforcement Administration and Homeland Security Investigations. As a result of the sanctions, all property and interests in property belonging to the sanctioned persons subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are also generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Persons that engage in certain transactions with the designated individuals or entities may themselves be exposed to sanctions or enforcement action, OFAC warned.

    Financial Crimes Department of Treasury OFAC SDN List OFAC Sanctions OFAC Designations Of Interest to Non-US Persons Drug Enforcement Administration Department of Homeland Security

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  • FTC seeks to protect highly sensitive data

    Privacy, Cyber Risk & Data Security

    On July 11, the FTC’s Division of Privacy & Identity Protection published a blog post addressing risks associated with the sharing of highly personal information with strangers, particularly with respect to the use of technology that directly observes or derives sensitive information about users. The FTC noted that aside from location information, which is often automatically generated from consumers’ connected devices, consumers are also actively generating sensitive health information, including personal reproductive data, through apps on their devices. This “potent combination of location data and user-generated health data creates a new frontier of potential harms to consumers,” the FTC warned, pointing to the “ad tech and data broker ecosystem where companies have a profit motive to share data at an unprecedented scale and granularity.” Additionally, once the sensitive information is collected, the FTC said that consumers usually have no idea who has access to it, what the information is being used for, or that companies are profiting from the sale of their data. “The misuse of mobile location and health information–including reproductive health data–exposes consumers to significant harm,” the FTC stated. “Criminals can use location or health data to facilitate phishing scams or commit identity theft . . . and may subject people to discrimination, stigma, mental anguish, or other serious harms.” The FTC reminded companies that it is committed to using the full scope of its legal authorities to protect consumers’ privacy and that it “will vigorously enforce the law” to protect the security and privacy of consumers’ personal information. Companies are advised that sensitive information is protected by several federal and state laws and that making claims that data is “anonymous” or “has been anonymized” may be a deceptive trade practice under the FTC Act if untrue. 

    Privacy, Cyber Risk & Data Security FTC Consumer Protection Third-Party Drug Enforcement Administration

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  • OFAC sanctions individuals connected to Mexican cartels

    Financial Crimes

    On June 2, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14059 against six individuals for engaging with a Mexico-based drug traffic organization. Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson stated that “[v]iolence and corruption have been critical to [the organization’s] growth in the past decade,” which has “fueled the cartel’s territorial expansion, and with it a greater capacity to traffic deadly drugs to the United States.” The sanctions are the result of a collaboration between Treasury, the Government of Mexico, and the U.S. Drug Enforcement Administration (DEA) with support from the U.S. Customs and Border Protection. As a result of the sanctions, the designated persons’ property located in the U.S. or held by U.S. persons is blocked and must be reported to OFAC. Additionally, OFAC regulations generally prohibit U.S. persons from participating in transactions with the designated persons.

    Financial Crimes Department of Treasury OFAC Of Interest to Non-US Persons SDN List Mexico OFAC Sanctions OFAC Designations Drug Enforcement Administration

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  • OFAC sanctions drug traffickers

    Financial Crimes

    On February 10, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14059 against two individuals for materially contributing to the illicit activities of major Mexican cartels to traffic drugs into the U.S. According to OFAC, the action, which was the result of collaboration between OFAC and the Drug Enforcement Administration, provides that all property and interests in property of sanctioned individuals in the U.S. or in the possession or control of U.S. persons must be blocked and reported to OFAC. OFAC notes that its regulations generally prohibit all transactions by U.S. persons that involve any property or interests in property of designated or otherwise blocked persons.

    Financial Crimes OFAC Mexico Of Interest to Non-US Persons Department of Treasury Ecuador SDN List OFAC Sanctions OFAC Designations Drug Enforcement Administration

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  • OFAC sanctions Mexican nationals

    Financial Crimes

    On October 6, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to the Foreign Narcotics Kingpin Designation Act against four individuals who are allegedly senior members of a Mexican-based drug cartel, which is said to be responsible for trafficking deadly drugs into the U.S. As a result of the sanctions, all property and interests in property subject to U.S. jurisdiction that belong to the sanctioned persons must be blocked and reported to OFAC. U.S. persons are also generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. OFAC further notes that the designations against the individuals were made in collaboration with the Drug Enforcement Administration and Mexico’s Financial Intelligence Unit.

    Financial Crimes Department of Treasury OFAC FinCEN SDN List OFAC Sanctions OFAC Designations Mexico Drug Enforcement Administration Of Interest to Non-US Persons

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  • OFAC sanctions Mexican cartel members and facilitator

    Financial Crimes

    On May 12, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to the Foreign Narcotics Kingpin Designation Act against a commander and his organization responsible for facilitating drug trafficking between Mexico and the U.S. OFAC also designated six other individuals and one entity as Specially Designated Narcotics Traffickers pursuant to the Kingpin Act for their connections to the organization. Director of OFAC Andrea Gacki noted that the sanctioned organization “help[s] fuel our nation’s opioid epidemic” and that “Treasury and our U.S. government partners, including the Drug Enforcement Administration, will continue to use every available resource to dismantle these criminal networks.” As a result of the sanctions, all property belonging to the sanctioned persons subject to U.S. jurisdiction are blocked and must be reported to OFAC. U.S. persons are also generally prohibited from engaging in any dealings involving the property of blocked or designated persons.

    These sanctions against the drug trafficking cartel are the most recent efforts taken by OFAC pursuant to the Kingpin Act (covered in InfoBytes, here and here).

    Financial Crimes OFAC Department of Treasury SDN List Of Interest to Non-US Persons Mexico Sanctions OFAC Designations Department of Justice Drug Enforcement Administration Department of Homeland Security

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