FinCEN Requests Comments Regarding Possible Relaxation of Banks’ Customer Identification Program Requirements

Reported by Caroline E. Brown, Nicole Sayegh Succar, Carlton Greene, and Anand Sithian On March 29, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), issued a “notice and request for information and comment” (“RFI”) seeking comments on the Bank Secrecy Act’s (“BSA”) customer identification program (“CIP”) rule.  The CIP rule requires […]

The Impact of Semiconductor Sanctions on Russia

Reported by Chris Miller (American Enterprise Institute) After Russia again invaded Ukraine in February 2022, the US and its allies restricted Russia’s access to semiconductors, aiming to cause disruption to the Kremlin’s defense industrial supply chains. Have these controls on semiconductors worked? The secrecy of the Russian defense industrial base makes it difficult to answer […]