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Dmitry Bergoltsev

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Dmitry Bergoltsev is a Senior International Trade Specialist I in Crowell & Moring’s Washington, D.C., office. With professional fluency in Russian and Mandarin, Dmitry bridges language and cultural barriers, offering valuable insights for clients navigating complex global trade and regulatory matters. He works closely with attorneys to develop practical solutions for clients facing challenges before the Office of Foreign Assets Control (OFAC), U.S. Customs and Border Protection (CBP), the Bureau of Industry and Security (BIS), and other federal agencies. Dmitry’s key areas of focus include advising clients on sanctions and export controls compliance, U.S. import and export regulations, and supply chain due diligence, with particular attention to the geopolitical and regulatory risks our clients face when operating across global markets.

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What You Need to Know

Key takeaway #1: On August 13, 2026, FinCEN issued a Financial Trend Analysis showing 67,540 Bank Secrecy Act (BSA) reports filed between 2023 and 2025 involved more than $4.9 billion in reported suspicious activity potentially related to human smuggling.

Key takeaway #2: Money services businesses (MSBs) filed approximately 97% of the reports, while depository institutions filed approximately only 3% but accounted for nearly 61% of the total reported suspicious activity.

Key takeaway #3: Financial institutions should consider whether the red flags and typologies highlighted in the FTA are appropriately incorporated into their automated transaction-monitoring scenarios for detecting potentially suspicious human smuggling-related activity.

Continue Reading Following the Money: FinCEN Maps the Financial Footprint of Human Smuggling

Key Takeaways 

  • The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated six individuals and entities tied to Cartel del Noreste (CDN)—one of Mexico’s most violent drug trafficking organizations—including two CDN-affiliated casinos used for money laundering and drug operations near the U.S.-Mexico border. 
  • OFAC’s actions are the latest examples of a broader national security strategy to use sanctions, AML authorities, criminal prosecutions, and other tools to counter cartels on the U.S.-Mexico border. These efforts have targeted in particular non-traditional financial institutions such as casinos, public-facing professionals, and disinformation actors. 
  • The State Department designated CDN as a foreign terrorist organization (FTO) on February 20, 2026, and today’s designations were issued under both Executive Order 14059 (narcotics trafficking) and Executive Order 13224 (terrorism), underscoring the U.S. government’s treatment of major cartels as hybrid criminal-terrorist threats.
Continue Reading OFAC Sanctions Cartel-Linked Casinos and Financial Enablers on the Southern Border 

What You Need To Know

  • The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued six new general licenses, and updated a seventh that allow for many activities related to: the export of Venezuelan oil and petrochemical products from Venezuela; the exploration, development, and production of oil, gas, and petrochemical products in Venezuela; the generation, transmission, storage, or distribution of electricity in Venezuela; the export to Venezuela of U.S.-origin diluents; negotiating for investment in the oil, gas, petrochemical, and electricity sectors in Venezuela; and the export of Venezuelan gold.
  • The new general licenses contain a number of significant conditions, including in GLs 46B and 51, a limitation to the activities of “established U.S. entities,” and in GLs 46B, 47, 48A, 50A, and 51, limits on counterparties and operators, a prohibition on the involvement of entities with specific relationships to China, Cuba, Iran, North Korea, and Russia, or of sanctioned vessels, and contractual requirements to use U.S. law and U.S. dispute resolution mechanisms.
  • This regulatory space is fast moving, with multiple changes occurring over a short time period, and any plan to rely on these general licenses and authorizations should include transaction-by-transaction assessment, along with monitoring by compliance and legal functions.
Continue Reading Eight Takeaways After Seven Weeks of OFAC’s Six — wait, Seven — New and Updated General Licenses for Venezuela