Industry players would be able to make smart decisions based on the results, Data Collection, Videos of Comp. [xiv] See U.S. Dept of the Treasury, Venezuela General License 8J (May 27, 2022); U.S. Dept of Treasury, Venezuela General License 8K (Nov. 26, 2022), available here. [vii] See Charlie Savage, U.S. [lxxvii] The Consent Order faulted USAAs failure to maintain an effective AML/BSA program despite having entered into a set of commitments in 2018 to remediate[lxxviii] The banks deficient practices included fail[ure] to perform adequate pilot testing before launching [a transaction monitoring] system and a backlog of around 90,000 un-reviewed alerts and 6,900 unreviewed cases.[lxxix] FinCEN also noted that the OCCwhich also issued a $60 million penalty due to the violations[lxxx]had warned USAA of these violations since 2018. 21, 2022), available here; U.S. Dept of Treasury, Office of Foreign Assets Control, OFAC Settles with Chisu International Corporation for $45,908 Related to Apparent Violations of the Cuban Assets Control Regulations (Apr. Available here. On April 21, 2022, OFAC announced a $141,442 settlement with Newmont Corporation (Newmont), a U.S.-based multinational mining firm, and a $45,908 settlement with Chisu International Corporation (Chisu), a U.S.-based company affiliated with a distributor of mining explosives, related to apparent violations of the Cuban Assets Control Regulations stemming from the same transactions. WebBuilding Information Search BIS is not reflecting some transactions made April 29 - May 6, 2022, as well as limited transactions prior to April 29 due to an unexpected power outage at According to DOJ, Skoch created a complex ownership structure for the aircraft that attempted to hide his ownership of the plane and make it appear that close family members of Skoch were actually the owners of the aircraft. [xi] The White House, Executive Order on Taking Additional Steps to Address the National Emergency with Respect to the Situation in Nicaragua (Oct. 24, 2022), available here. If the owner repairs the problem and has it inspected and certified before that date, the hearing is cancelled and a new or revised Certificate of Occupancy is issued. A Trellis Expert will contact you to discuss the best options for your business. 7 at 8. [xxiv] Nikkilesh De, Crypto Engineers, Investors Sue U.S. Treasury Over Tornado Cash Sanctions, (Sept. 8, 2022), Coin Desk available here. I got that question today and I took a moments pause. [xii], Venezuela. FinCEN Advises Increased Vigilance for Potential Russian Sanctions Evasion Attempts. As discussed in our prior memoranda,[ii] when Russias invasion of Ukraine began, the U.S. government reacted by issuing broad-ranging blocking sanctions targeting major Russian financial institutions and state-owned entities (including Sberbank, Alfa Bank VTB Bank, Alrosa, and the Russian Direct Investment Fund), as well as additional prominent Russian companies and individuals. As discussed in our prior memorandum,[xxxviii] on October 11, 2022, Bittrex, a U.S.-headquartered cryptocurrency exchange, agreed to a settlement with OFAC to resolve 116,421 apparent violations of multiple sanctions programs for approximately $24,280,829. [xxxii] According to OFAC, BPPR processed 337 transactions totaling $853,126 on behalf of two individuals who were low level employees of the Government of Venezuela (GoV), in apparent violation of U.S. sanctions against Venezuela. WebHPD Online Use HPD Online to find building data and information about complaints and litigation, property registration, violations and charges, and block and lot information. [xcviii] According to DOJ, following his designation as an SDN, Deripaska used various shell companies to maintain luxury properties in the United States and employed associates to engage in transactions for his benefit in the United States and using the U.S. financial system. Use the Step by Step tool to get an exhaustive list of requirements that matter to you. However, the disclosure did not qualify as voluntary self-disclosure because OFAC was already in possession of the relevant information. -Great markets with a high population [clxii] Finally, DFS found that Robinhood Crypto relied on its parents policies without ensuring that they met DFS standards. [ci] DOJ Press Release, Arrest and Criminal Charges Announced Against British and Russian Businessmen for Facilitating Sanctions Evasion of Russian Oligarchs $90 Million Yacht, (Jan. 23, 2023), available here. Hi Sara! Real estate partner Salvatore Gogliormella and litigation partner Roberto Gonzalez have been named to Law360's Rising Stars for 2016 in the Real Estate and Banking categories, respectively. Although OFAC had issued General License 34A (GL 34A), OFAC found BPPRs failure to identify the two employees for 14 months after the Executive Order was issued (where the bank possessed documentation at the time of the Executive Order showing that the individuals were employees of GoV) to be an aggravating factor in calculating the monetary penalty; however, OFAC found the case to be non-egregious, citing as mitigating factors enhancements to BPPRs program to better ensure compliance with OFAC sanctions. [lxviii]Noting that financial institutions are uniquely situated to detect possible financial exploitation, FinCEN called on financial institutions to identify, prevent, and report EFE to law enforcement and relevant Adult Protective Services at the state level. Additionally, in an unprecedented move, OFAC, in coordination with the European Union, also arranged for seven Russian banks to be removed from the SWIFT messaging system. [xvii] OFAC explained that it issued GL41 consistent with longstanding U.S. policy to provide targeted sanctions relief based on concrete steps that alleviate the suffering of the Venezuelan people and support the restoration of democracy.[xviii] GL 41s issuance also coincided with significant changes in the domestic politics of Venezuela at the end of 2022 and beginning of 2023, including, most notably, the Venezuelan oppositions removal of Juan Guiado as Interim President, a position he had held since 2019, and shifting coalitions in the Venezuelan National Assembly. [xlvii] According to OFAC, the violations were related to an invoice from August 2015 issued to Russias largest oil producer Rosneft (an SSI-listed entity), by a company that was acquired by S&P Global in 2016. Lafarge Pleads Guilty to Material Support Charge. Litigation partner Jessica Carey was named to Crains New York Businesss 2022 Notable Women in Law list, celebrating talented female attorneys in the New York City metropolitan area. Put yourself out there, network and share ideas. DOB Office Locations:Office Locations - Buildings (nyc.gov). Elevator License Exam Payment. This memorandum also surveys two additional topicsthe Treasury Department and DOJs follow up to President Bidens whole-of-government crypto executive order, and recent developments in the work of the Financial Action Task Force (FATF). [xliv] Most of the violative transactions occurred within hours after OFAC had designated the two individuals. [clxxxii] U.S. Dept of Justice, Justice Department Announces Report on Digital Assets and Launches Nationwide Network (Sept. 16, 2022), available here. On August 16, 2022, the FRB released guidance for all FRB-supervised banking organizations engaging in activities involving cryptocurrency that seeks to address risks related to ensure safety and soundness, consumer protection, and financial stability. [lxviii] FinCEN, Advisory on Elder Financial Exploitation, FIN-2022-A002, available here. [clxix] Coinbase will pay a $50 million penalty for violating the New York Banking Law and DFS virtual currency, money transmitter, transaction monitoring, and cybersecurity regulations. Further, authorized recipients who are given access to BOI must only use the information in furtherance of the activity for which it was disclosed and must implement specific safeguards that protect against unauthorized disclosure. [cxiii] U.S. Dept of Justice, High-Ranking Employee At Cryptocurrency Exchange Pleads Guilty To Bank Secrecy Act Violations (Aug. 8, 2022), available here. [clxxxiii] It also identified the initiatives that the DOJ and law enforcement agencies have established as part of whole-of-government efforts to more effectively detect, investigate, prosecute, and otherwise disrupt these crimes; and recommended regulatory and legislative actions to further enhance law enforcements ability to address digital asset crimes. FinCEN noted several characteristics of the commercial real estate industry that rendered it particularly vulnerable to exploitation by sanctioned individuals and entities, including, inter alia, highly complex financing methods and opaque ownership structures. [lxxv] U.S. Dept of Treasury, Financial Crimes Enforcement Network, FinCEN Assesses $275,000 Civil Money Penalty against A&S World Trading for Violating Geographic Targeting Order (Apr. Your content views addon has successfully been added. The violation is entered against the property in the Department's Buildings Information System (BIS), and must be corrected before a new or These cookies do not store any personal information. Frozen Sandwiches Market The Latest survey report on Global Frozen Sandwiches Market sheds lights on changing dynamics in Food & What is Market Research? You can find [lxxxi] FinCEN credited the OCC $60 million penalty against the $140 million figure.[lxxxii]. The comment period closed on February 14, 2023. of Currency, Agreement Between Blue Ridge Bank and the Off. Use of portable #xray units is still allowed in some states, however, many states are changing their #radiology regulations to prohibit use of a portable x-ray unit unless using a portable unit is medically necessary due to no access to a fixed unit. On March 7, 2022, FinCEN issued an alert notifying all financial institutions about attempts to evade sanctions on the Russian financial services sector in response to the invasion of Ukraine. Nearly half of this penalty figure was attributable to its first-ever enforcement action against a cryptocurrency exchange, Bittrex. [lxiv] U.S. Dept of Treasury, FinCEN and the U.S. Department of Commerces Bureau of Industry and Security Urge Increased Vigilance for Potential Russian and Belarusian Export Control Evasion Attempts, FIN-2022-Alert003 (June 28, 2022), available here. Danske Bank Estonia processed $160 billion through U.S. banks on behalf of these customers. We will email you this document within 4 business hours. Bittrex. DOB violations are shown without an asterisk next to the violation number; dismissed DOB violations are shown with an asterisk, e.g., V*7052-18P. If you need immediate assistance, please contact support@trellis.law. [lxvii] U.S. Dept of Treasury, FinCEN Alert on Human Smuggling along the Southwest Border of the United States, FIN-2023-Alert001 (Jan. 13, 2023), available here. Unprecedented Sanctions Targeting Russia. [xlv] U.S. Dept of Treasury, OFAC Settles with Newmont Corporation for $141,442 Related to Apparent Violations of the Cuban Assets Control Regulations (Apr. [cxxi] The rules goal is to harmonize the OCC with FinCEN, and allow both agencies to grant exemptions to a national bank or federal savings association [that] has a novel SAR-related proposal which does not squarely fit into the regulatory requirements but would be consistent with anti-money laundering regulatory and safety and soundness standards.[cxxii] For example, an innovative approach may involve[e] SAR-sharing across institutions but this may violate prohibitions against disclosures of SARs.[cxxiii], Statement on Engagement in Crypto-Asset-Related Activities. Ive shared this story numerous times. Since the task forces establishment in March, DOJ has worked with international partners to (i) seize a nearly $90 million dollar yacht belonging to a sanctioned Russian oligarch; (ii) seize millions of dollars associated with sanctioned parties held at multiple U.S. financial institutions; and (iii) seize luxury aircraft and to publicly expose the opaque corporate structures masking the ownership of those assets. 1) portable x-ray units are very low powered. The healthcare leader paused when I was done and then shared, its not for us but I can introduce you to someone who might be interested. As relevant here, the EO noted the role of digital assets in sophisticated cybercrimerelated financial networks and activity, including through ransomware activity.[clxxvi] The EO called for a cross-governmental team of law enforcement agencies to submit multiple reports to address this riskincluding one that is to be submitted to Congress on the trends in the use of digital assets by illicit actors. Paul, Weiss, Rifkind, Wharton & Garrison LLP, Economic Sanctions & Anti-Money Laundering, Firm chairman Brad Karp, corporate partner Mark Bergman and litigation partners Susanna Buergel, Roberto Gonzalez, Jane OBrien and Elizabeth Sacksteder have been selected to receive the, Firm chair Brad Karp was named a 2017 Litigator of the Year by, Litigation partners Jessica Carey and Roberto Gonzalez have been selected to receive the . Despite having such information, OFAC determined that CAIS allowed customers to purchase securities in 240 transactions totaling $2,050,780 and to engage in 33 separate commercial transactions totaling approximately $1,025,400, in each case these transactions were processed through the U.S. financial system. [xxv] The amendments raised the applicable statutory maximum civil penalty amounts to $356,579 per violation of the International Emergency Economic Powers Act (IEEPA) and $105,083 per violation of the Trading With the Enemy Act (TWEA). 20-CR-500 (S.D.N.Y.). For the period January 1, 2014 through June 30, 2016, a total of 90,861 construction noise complaints were called in to New York . Zoning Challenge. OFAC took the view that this re-dating and re-issuing of the invoices, the first instance of which occurred 374 days after the invoice for the debt was originally issued and the last of which occurred 749 days after the original invoice was issued, violated Directive 2 of the Ukraine-related sanctions, which prohibits all transactions or other dealings in new debt of Rosneft of longer than 90 days maturity. April 4, 2022, What is Market Research? About DOB NOW. [clxiii] https://www.dfs.ny.gov/reports_and_publications/press_releases/pr202202241. [lxx] FinCEN, FinCEN Announces $29 Million Enforcement Action Against Virtual Asset Service Provider Bittrex for Willful Violations of the Bank Secrecy Act (Oct. 11, 2022), available here; OFAC, Treasury Announces Two Enforcement Actions for over $24M and $29M Against Virtual Currency Exchange Bittrex, Inc. (Oct. 11, 2022), available here (OFAC Press Release). Valorous Floating Wind Farm Site Hosts USV Seabed-to-Desk Data Collection Demo, Data Center Construction Market Size, Scope and Forecast, Global Automatic Emergency Braking System (AEBS) Market Intelligence 2022, MATLAB Tools for Scientists: Introduction to Statistical Analysis, Introduction to Market Research (Components of Market Research), Frozen Sandwiches Market to See Huge Growth by 2027, Intro to Data Analysis / Visualization with Python, Matplotlib and Pandas | Matplotlib Tutorial, A little blind: Officials, health experts frustrated after State Health Department stops publishing local COVID-19 data | State and Regional News, RV Reducer Market Size by Top Companies, Trends by Types and Application, Forecast to 2028, 2.1. [lix] FinCEN has urged financial institutions to file suspicious activity reports and conduct customer due diligence as appropriate. A comprehensive overview of Russian sanction is beyond the scope of this memorandum. All violations issued are public information and can be viewed online on the Buildings Information System (BIS). OFAC also designated hundreds of Belarussian individuals and entities in response to Belarus support for the invasion. [cliv] https://www.dfs.ny.gov/industry_guidance/industry_letters/il20220428_guidance_use_blockchain_analytics. OFACs 16 public enforcement actions highlight OFACs broad assertion of jurisdiction and its increasing focus on non-U.S. companies. Blender.io Designation. Due to concerns over Nicaraguan President Daniel Ortegas efforts to jail opposition politicians, undermine the legitimacy of the 2021 Nicaraguan presidential election, and impose other restrictions on Nicaraguans freedoms of expression and assembly, in June 2022 OFAC announced the designation of the Nicaraguan state-owned gold company, ENIMINAS, and the president of its board of directors on the SDN List. [l] The CTA requires Reporting Companies to report BOI to FinCEN, and FinCEN will in turn establish a BOI database. These cookies will be stored in your browser only with your consent. Afghanistan. WebOnce the NYC Department of Buildings (DOB) is notified, usually by a tenant or concerned neighbor, of a non-compliance issue, the department commissioner sends out a notice and an order to correct the violation. This will halt all forward motion in construction and the selling of the property until the violations are cleared up. The U.S. government also imposed prohibitions on the importation into the United States of Russian-origin energy products (e.g., crude oil, petroleum, liquified natural gas, coal) and Russian-origin fish, seafood, alcohol, and diamonds. Executive Order 13884 was issued on August 5, 2019, blocking property and interests in property of the GoV, including the property and interests in property of government officials and employees of the GoV. The processing fee is $8.00 per copy for each violation; each additional duplicate copy of a violation is $5.00. As discussed in our prior memorandum,[cix] in August 2021, the SDNY indicted crypto derivatives exchange BitMEX founders Arthur Hayes, Benjamin Delo, and Samuel Reed, and BitMEX former executive Gregory Dwyer on charges of violating the BSA and conspiracy to violate the BSA. This is a statement that the FDA had released several years ago, which has been adopted by many states. The U.S. District Court for the District of Columbia issued the seizure warrant, calling the seizure of the yacht just the beginning of the reckoning that awaits those who would facilitate Putins atrocities. [cxx] Off. 8, 2022), available here. [vid_likes] - 1473351556 - data collection sheet, Free MATLAB Trial: Request a Quote: Contact Us: Learn more about MATLAB: [vid_likes] - 1498760598 - data analysis tools, [vid_likes] - 1491399396 - Market Research. [clxxxiv] On the same day, DOJ announced the establishment of the nationwide Digital Asset Coordinator Network, which is to serve as the primary forum for prosecutors to obtain and disseminate specialized training, technical expertise, and guidance about the investigation and prosecution of digital asset crimes. The proposed rule outlines circumstances in which authorized recipients can request access to the BOI contained in FinCENs database and the data protection protocols and oversight mechanisms that apply. [xliii] U.S. Dept of Treasury, OFAC Issues a Finding of Violation to Nodus International Bank, Inc. for Violations of the Venezuelan Sanctions Regulations and the Reporting, Penalties and Procedures Regulations (Oct. 18, 2022), available here. [cxlii] https://www.sec.gov/news/press-release/2022-85. [xlviii] According to OFAC, Heritage Trust holds assets valued at over $1 billion. Nodus International Bank. Depending on the severity of the violation, it can be used as a premise for a criminal court summons and prosecution. Alert on Human Smuggling in Southwest U.S. Border. [cvii] Paul, Weiss, Economic Sanctions and Anti-Money Laundering Developments: 2020 Year in Review (Feb. 22, 2021), available here; Paul, Weiss, Economic Sanctions and Anti-Money Laundering Developments: 2021 Year in Review (Feb. 10, 2022), available here. Nodus voluntarily self-disclosed these transactions to OFAC. 28, 2022), available here. for this document. WebSearch. The Global Table Linen Market 2022 research report is based on an exhaustive study of the market, enabling customers to gain access to potential forecasts and requirements. Family Office & High-Net-Worth Individuals, Biden Administration Resource Center for Businesses, https://www.cbo.gov/system/files/2022-11/hr7195.pdf, Economic Sanctions and Anti-Money Laundering Developments: 2022 Year in Review, John Carlin to Discuss Trajectory of Regulations and Enforcement at Kharon Global Summit, DOJ and FinCEN Take Coordinated Action Against Bitzlato Cryptocurrency Exchange and Its Owner, OFAC Enforcement Action Targets U.S.-Incorporated Cryptocurrency Exchange for Apparent Violations of U.S. Sanctions, David Kessler Co-Chairs NYSBA Panel on Financial Regulation and Money Laundering, David Fein to Discuss Money Laundering and Environmental Crimes at German Ministry of Finance Event, Roberto Gonzalez and Jessica Carey Author Expert Analysis Chapter in GLIs, The DOJ Charges Thirteen Individuals in Three Different PRC Espionage Cases, Signaling a New Enforcement Phase, DOJ Prosecutions Reflect Aggressive Stance Toward Russian Sanctions and Export Control Evasion, John Carlin Discusses Evolution of Cybersecurity at the DOJ and His Move to Paul, Weiss With, Jessica Carey Named Notable Woman in Law by. [cxxix] The agency had previously warned ICICI of these violations. Adding your team is easy in the "Manage Company Users" tab. of Comp. [cxliv] The SEC charges that Danske Bank knew or should have known that a substantial portion of the Estonian branchs customers were engaging in transactions within the United States and other countries with a high risk of money laundering, and that the Estonian branchs AML infrastructure was insufficient to prevent money laundering. I was on the Jersey Shore, between treating patients as a physical therapist doing house calls. Your credits were successfully purchased. I would also addcost. The rule applies to corporations, limited liability companies, and other similar entities registered in the United States, as well as non-U.S. companies registered to do business in the United States, but exempts 23 types of entities from reporting requirements, including: SEC reporting issuers, banks, credit unions, tax exempt entities, broker-dealers, investment companies and their advisors, and companies that have (i) 20 or more full-time employees, (ii) $5 million in annual revenue, and (iii) a physical office within the United States. To view violations on your property, access the, Detailed information on certain DOB violations is available in BIS. 17, 2022), available here. Great post, I find myself simply answering: We work on goals to target your child's struggles in Language, Social Skills and Behavior. & Exch. 2022) available here. 10 (plea agreement) and Dkt. 21, 2022), available here. by ", 2023 Paul, Weiss, Rifkind, Wharton & Garrison LLP. In the guidance, OFAC goes on to describe new tools and technologies that financial institutions could use to mitigate their sanctions risks with respect to instant payment systems. 87 Homes For Rent in Racine, WI. On April 6, 2022, DOJ unsealed an indictment charging Konstantin Malofeyev, a Russian oligarch and SDN, with conspiracy to violate U.S. sanctions and violations of U.S. sanctions in connection with his hiring of Jack Hanick, as described above. WebYou can get information about Department of Buildings (DOB) violations online through the Buildings Information System (BIS) or at a DOB Borough Office. NLP (neurolinguistic programming) is a powerful and popular way to leverage familiar brain (ie neuro) processing patterns (ie programming) around language and thoughts (ie linguistic). WebECB Violations - NYC CityPay | City of New York CityPay Home Search for Tickets (Office of Administrative Trials and Hearings - OATH) There are three ways to search: By Ticket This button displays the currently selected search type. In waves of designations in the months following the invasion, OFAC added hundreds of Russian individuals and entities to the SDN List. OFAC found that Danfosss global sanctions compliance program was deficient because there were no procedures to regularly monitor Danfoss FZCOs activities to identify potential sanctions issues. [lxxviii] FinCEN, Consent Order, In the matter of USAA, at 5 (March 17, 2022), available here. This appears to be the first bank regulator action against a bank for processing fraudulent PPP loans. Accessing Verdicts requires a change to your plan. Moreover, the company failed to correct these failures even after the Internal Revenue Service (IRS) identified the 114 missing GTO reports during an examination in September 2015. In February 2022, President Biden issued an executive order that declared a national emergency with respect to the humanitarian situation in Afghanistan and ordered that all of the property and interests in property of Da Afghanistan Bank (DAB), the central bank of Afghanistan, held in the United States be blocked and transferred to a consolidated blocked account held at the Federal Reserve Bank of New York. A violation filed against the property will prevent the owner from selling or refinancing it or obtaining construction permits, until the issue is resolved and the violation erased from the online record. 202203, at 2, available here. WebA DOB Violation is a notice that a property is not in compliance with some provision of applicable law and includes an order from the Commissioner of the Department of [xliii] In 2017, a Nodus customer (an individual) was added to the SDN List and Nodus decided to sever all ties with the customer. WebThe table below defines the parking violation codes in New York City and lists the fines. [clxxv] Executive Order, supra note 173. 3) Many states are concerned that people purchase portable units to avoid shielding an area where x-rays are performed. on Banking, Housing, and Urban Affs., 117th Congress (Sept. 20, 2022) (statement of Andrew Adams, Director of KleptoCapture Task Force), available here. If a building is not in compliance with the DOBs laws, it will get issued a violation. of Comp. 4, 2022), available here. If you are working on a construction site and want to avoid violations, then we suggest you work with a professional to ensure you meet all regulations and safety protocols. FinCEN found that A&S failed to report at least 114 cash transactions totaling approximately $2,330,000, violating the reporting and recordkeeping requirements of the GTO. You can also search for information [lxxx] OCC, Consent Order, In the Matter of USAA, at 3 (March 17, 2022), available here. Failing to maintain the inside temperature at 68 degrees when the outside temperature is below 55 degrees during the day, or Exposure to the #radtech and patients is greater with portable units than with fixed units. Open violations can prevent an owner from selling or refinancing. [xxxvii] As in the related CA Indosuez (Switzerland) S.A enforcement action, OFAC determined CFM had reason to know of these violations given that the account holders know-your-customer files included address information indicating that they were resident in comprehensively sanctioned jurisdictions and that CFM had failed to implement and maintain the sanctions compliance framework of its parent company. [xxxvii] U.S. Dept of Treasury, OFAC Settles with CFM Indosuez for $401,039 Related to Apparent Violations of Multiple Sanctions Programs, (Sept. 26, 2022), available here. [xvii] U.S. Dept of Treasury, Treasury Issues Venezuela General License 41 Upon Resumption of Mexico City Talks (Nov. 26, 2022), available here. Services, DFS Superintendent Harris Announces $30 Million Penalty on Robinhood Crypto for Significant Anti-Money Laundering, Cybersecurity & Consumer Protection Violations (Aug. 2, 2022), available here (hereinafter, the DFS Press Release). On April 25, 2022, OFAC announced a $6,131,855 settlement with Australia-headquartered Toll Holdings Limited (Toll) related to 2,958 apparent violations of multiple sanctions programs, including transactions with individuals on the SDN List as well as transactions involving North Korea, Iran, and Syria. But it's also the driving force behind a lot of problematic marketing. [li] Specifically, the proposed rule provides that FinCEN may only disclose BOI to (i) federal agencies engaged in national security, intelligence, or law enforcement activities; (ii) state, local, and Tribal law enforcement agencies that obtain court authorization; (iii) U.S. Department of the Treasury officers and employees who require access in order to perform their official duties; (iv) certain authorized foreign law enforcement agencies and judicial and government authorities; and (v) financial institutions that need the information in order to comply with FinCENs 2016 CDD rule, provided that the relevant reporting company has consented to the disclosure.