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Washington, D.C. (August 20, 2024) - In a June 12, 2024, guidance document, the U.S. Treasury Department's ('Treasury') Office of Foreign Assets Control ('OFAC') announced a new interpretation that significantly [...]

Washington, D.C. (October 22, 2024) - On September 30, the U.S. Department of the Treasury's Office of Foreign Assets Control ('OFAC') issued a new General License ('GL') and updated its [...]

Washington, D.C. (October 25, 2024) - On July 26, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control ('OFAC') announced a substantial $7,452,501 settlement with State Street [...]

In recent weeks, the US Department of the Treasury's Office of Foreign Assets Control ('OFAC') has introduced an interim and a final rule amending its regulations with important implications for [...]

On Oct. 10, 2024, the US Department of the Treasury's Office of Foreign Assets Control ('OFAC') issued guidance relating to the designation of the National Settlement Depository ('NSD') in response [...]

On October 30, 2024, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) announced new sanctions against 275 individuals and entities, including sanctions against individuals involved in [...]

Introduction In recent years, economic sanctions have become an increasingly important U.S. foreign policy tool and the digital asset industry has become a key focus of sanctions regulators and prosecutors. [...]

Key Takeaways: OFAC has published an Updated Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors, following a Maritime Oil Advisory it issued in October 2023. The [...]

The practice of determining an item's country of origin ('COO') and utilizing the principal of 'substantial transformation' to help make this determination is likely a familiar concept for many U.S. [...]

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued a final rule that revises certain provisions related to the voluntary self-disclosure (VSD) process for exporters who believe [...]

Key Takeaways: OFAC issued an interim final rule extending OFAC's recordkeeping requirements from 5 years to 10 years, to comport with the corresponding statute of limitations extension. OFAC also published [...]

In an era of active U.S. sanctions policy, it is not uncommon to see the Office of Foreign Assets Control ('OFAC') issue a notice changing U.S. sanctions - promulgating a [...]

On September 11, 2024, the Department of the Treasury's Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (the IFR), effective March 12, 2025, that extends OFAC's general [...]

An Alert on Russian Financial Institutions' Sanctions Evasion is Issued, a General License is Issued, and Russian Individuals and Organizations Related to Efforts to Influence the 2024 U.S. Presidential Election [...]

Key Takeaways: OFAC has released guidance regarding the extension of the statute of limitations, from 5 to 10 years, for violations of the International Emergency Economic Powers Act ('IEEPA') and [...]

I. US SANCTIONS U.S. Department of the Treasury Sanctions Leader and Primary Member of Cyber Army of Russia Reborn: On July 19, the U.S. Department of the Treasury's Office of [...]

In conjunction with the Group of Seven (G7) leaders meeting in Italy earlier this month, key jurisdictions issued the latest in a series of coordinated economic restrictions on Russia in [...]

On June 20, 2024, the Department of Commerce's Bureau of Industry and Security (BIS) issued a Final Determination ('Determination') prohibiting Kaspersky Lab, Inc.-the US subsidiary of the Russia-based antivirus software [...]

Highlights The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced updated guidance expanding the categories of transactions subjecting Foreign Financial Institutions (FFIs) to U.S. secondary sanctions. [...]

Last year, we published an update on BIS's foray into prohibiting EAR99 items for export to Russia and Belarus. We noted (somewhat in jest) that kitchen sinks may one day [...]

Washington, D.C. (June 18, 2024) - The Department of the Treasury's Office of Foreign Assets Control ('OFAC') published a final rule in the Federal Register on May 29, 2024 amending [...]

1. OFAC Amends Reporting Requirements and Procedures On May 10, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (IFR), effective [...]

On April 24, 2024, President Joe Biden signed into law an emergency supplemental appropriations bill for foreign aid ('Supplemental Act'), which includes several sanctions-related provisions, such as the 21st Century [...]

On May 29, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) implemented a final rule amending the Cuban Assets Control Regulations (CACR). OFAC stated that [...]

Highlights The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR), 31 CFR Part 515, to promote internet freedom in Cuba, [...]

Key Points On May 10, 2024, OFAC issued an IFR that would amend its Reporting, Procedures and Penalties Regulations (RPPR) at 31 C.F.R. Part 501 to, among other things, modify [...]

Last week, the Office of Foreign Assets Control (OFAC) announced an interim final rule which amends the recordkeeping and reporting requirements relating to the various economic sanctions programs it enforces. [...]

On December 22, 2023, President Biden signed a new Executive Order (E.O. 14114) containing the latest round of sanctions against the Russian Federation. Shortly thereafter, Treasury Secretary Janet Yellen stated [...]

Key Takeaways: OFAC announced two new Determinations. One bans the import into the U.S. of aluminum, copper, and nickel originating in Russia, while the other outlaws the provision of certain [...]

On March 14, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced that EFG International AG (EFG), a Switzerland-based bank, had agreed to pay roughly $3.74 million to [...]

Highlights The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), U.S. Department of Commerce's Bureau of Industry and Security (BIS) and U.S. Department of Justice (DOJ) issued [...]

On March 6, 2023 the US Department of Justice ('DOJ'), the US Department of Commerce ('Commerce Department'), and the US Department of the Treasury's Office of Foreign Assets Control ('OFAC'), [...]

The U.S. Department of Treasury's Office of Foreign Assets Control ('OFAC') last week issued updated guidance for various U.S. sanctions programs. These included a planned expiry of temporary sanctions relief [...]

On February 1, 2024, the United States Department of Treasury's Office of Foreign Assets Control ('OFAC') published a Price Cap Coalition Compliance and Enforcement Alert (the 'Alert'). Per the Alert, [...]

Washington, D.C. (February 2, 2024) - On December 22, 2023, the Office of Foreign Asset Control (OFAC) issued a Sanctions Advisory that provides guidance to 'foreign financial institutions that conduct [...]

The US Department of the Treasury's Office of Foreign Assets Control ('OFAC') on January 30, 2024, designated two cybersecurity experts affiliated with the Islamic State of Iraq and Syria ('ISIS') [...]

US Sanctions | EU Sanctions | UK Sanctions | Russia/Ukraine Sanctions | Other Notable Developments I. US SANCTIONS US Department of the Treasury Targets Price Cap Violation-Linked Shipping Company: On [...]

On August 10, 2023, the U.S. Department of the Treasury's Office of Foreign Assets Control ('OFAC'), in coordination in the United Kingdom and Canada, designated the former governor of Lebanon's [...]

I. US SANCTIONS OFAC and State Impose Additional Russia Sanctions: On Thursday, July 20, the US Department of the Treasury's Office of Foreign Assets Control ('OFAC') and the State Department [...]

On July 20, 2023, the United States Department of the Treasury's Office of Foreign Assets control ('OFAC') sanctioned multiple entities and issued general licenses to further implement the commitments made [...]

On July 11, 2023, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued Hostages and Wrongful Detention Sanctions Regulations (Regulations). The Regulations were issued pursuant to Executive Order [...]

Following an attempted revolt against Russian President Vladimir Putin in late June, the Department of the Treasury's Office of Foreign Asset Control ('OFAC') issued economic sanctions against several entities associated [...]

The US Department of the Treasury's ('Treasury') Office of Foreign Assets Control ('OFAC') announced on May 30 that it had sanctioned 17 Chinese and Mexican individuals and entities based upon [...]

On June 27, 2023, the United States Department of the Treasury's Office of Foreign Assets Control ('OFAC') imposed sanctions on various entities and one individual connected to the Russian mercenary [...]

1. Enforcement Roundup: FCPA, Crypto, and Anti-Boycott Actions Crypto Asset Company Settles Sanctions Violations for $7.5 million On May 1, the U.S. Department of Foreign Assets Control (OFAC) announced a [...]

On May 19, 2023, the US Treasury Department's Office of Foreign Assets Control ('OFAC') and the US Department of State announced a new round of multifaceted sanctions against Russia. These [...]

On April 25, 2023, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $508 million settlement with British American Tobacco p.l.c. (BAT)-one of the world's [...]

Key Takeaways: BIS and OFAC collectively imposed over $3.3 million in civil penalties against Microsoft as part of settlement agreements stemming from violations of U.S. export controls and sanctions laws. [...]