All in Regulatory Update

On March 2, 2023, the Department of Commerce, Department of the Treasury, and Department of Justice issued a Tri-Seal Compliance to constrain the use of third-party intermediaries or transshipment points to circumvent restrictions, disguise the involvement of Specially Designated Nationals and Blocked Persons (SDNs) or parties on the Entity List in transactions, and obscure the true identities of Russian end users. The Compliance Note highlights several of these tactics to assist the private sector in identifying warning signs and implementing appropriate compliance measures.

On March 2, 2023, the OFAC sanctioned eight Mexican companies linked to timeshare fraud on behalf of the Cartel de Jalisco Nueva Generacion (CJNG). A timeshare is a shared ownership model of vacation real estate in which multiple purchasers own allotments of usage in the same property. Timeshare fraud happens when scam artists call sellers of timeshares, posing as a reseller or real estate agent, then claims to have a buyer for the timeshare or guarantees he can sell the timeshare for a good price.

On March 1, 2023, the CFPB released a new issue spotlight examining how the financial products used to deliver public benefits, like Social Security and unemployment compensation, affect individuals’ ability to fully access the assistance provided through those programs. The issue spotlight outlines how governments often choose to deliver public benefits through financial products, particularly prepaid cards, that may subject recipients to high fees and cut into the amount of funds the consumer receives. 

On February 16, 2023, the CFPB published a summary of its key findings after the Bureau requested information from the largest credit card companies in the U.S. regarding their practices around suppressing actual payment information from the nationwide consumer reporting system. These companies included JPMorgan Chase, Citibank, Bank of America, Capital One, Discover, and American Express.