Publications, Presentations & Events

New York Limited Liability Companies will be subject to beneficial ownership reporting obligations pursuant to the New York LLC Transparency Act (NYLLCTA) beginning in 2026. This article discusses the requirements and potential penalties for failure to comply.

On November 24, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed a penalty of $4,677,552 on an individual in the real estate sector for knowingly renovating and selling property in Atlanta owned by a blocked individual. The investor, “U.S. Person-1,” not only violated OFAC’s Russia sanctions program, but failed to comply with an OFAC subpoena and violated the terms of an OFAC cease-and-desist letter.

On November 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions on a global network of individuals, entities, ships, and aircraft for their involvement with the Iranian regime.  The alleged network was sanctioned pursuant to OFAC’s counterterrorism authority, as set forth in Executive Order (E.O.) 13224, as amended and pursuant to the Iranian Sanctions regime, E.O. 13846 and 13902.

In an article published in the Fall edition of the International Academy of Financial Crime Litigators Bulletin, Adam Kaufmann and Eric Lewis examine new guidance from the Department of Justice on FCPA enforcement. 

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed former Paraguayan President Horacio Manuel Cartes Jara and several affiliated companies from its Specially Designated Nationals (SDN) list, reversing measures that had been in place for nearly three years under the Global Magnitsky Human Rights Accountability Act.