Photo of A. Joseph Jay, III

A. Joseph Jay, III

Subscribe to A. Joseph Jay, III's Posts

Joseph Jay is a white collar defense and government investigations partner in the firm's Washington, D.C. office.

Contact:Read more about A. Joseph Jay, III

On July 22, 2024, the Department of Treasury, Office of Foreign Assets Control (OFAC) announced a significant planned extension to its recordkeeping requirements, which will increase the retention period from five to ten years. OFAC expects to publish an interim final rule to provide an opportunity to comment. The change will increase compliance obligations for entities engaged in transactions subject to U.S. sanctions.Continue Reading SoL Long to Short Limits: The Sequel — A Decade of Recordkeeping and Enforcement

This article originally appeared on Law360 on June 9.

The novel coronavirus and resulting global health pandemic and economic crisis created a perfect storm for bad actors to engage in fraud and financial crimes. Law enforcement’s response to the criminal activity spurred by the pandemic and economic stimulus and relief efforts are still nascent and focusing on low hanging frauds by individuals and small groups.
Continue Reading Another COVID-19 Enforcement Tool: Money Laundering Law

*This is an updated version of the December 10th blog post.

Key Takeaways:

  • Emerging technology sectors are being reviewed now for new export controls that could take effect in 2019 (list below).
  • You may submit comments on the criteria the U.S. government will use to determine what technologies are subject to export controls.
  • The deadline for comments has been extended to January 10, 2019.
  • We can help.

Continue Reading Comment Deadline Extended: Export Controls on Emerging Technologies

Key Points

1. All sanctions on Iran that were in place before January 2016 will be re-imposed no later than November, 4 2018.

2. Secondary sanctions that penalize non-U.S. persons doing business with Iran will be reinstated.

3. General License H, allowing non-U.S. subsidiaries of U.S. companies to do business in Iran, will be revoked.

4. In some cases, companies may take payments or repayments for sales, loans, or credits to Iran after November 4, 2018
Continue Reading Client Alert: Iran Sanctions Return