News & Analysis as of

Office of Foreign Assets Control (OFAC) Foreign Relations

Morgan Lewis

OFAC Extends Reach Over Securities Held by Russia’s National Settlement Depository

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OFAC’s new FAQ 1097, issued October 10, warns US investors of the need to block securities held at Russia’s National Settlement Depository (NSD), even if the securities or the issuer is not sanctioned. Even if the security is...more

Locke Lord LLP

OFAC Issues FAQs for IT and Software ‎‎Services and Extends Authorization to Engage in ‎Administrative ‎Transactions in Russia

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On September 24, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three frequently asked questions (“FAQs”) that provide guidance to U.S. companies regarding the Determination...more

Locke Lord LLP

OFAC Takes Action Against Russian ‎Political Disinformation and ‎New Sanctions Evasion Tactics

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Russian Political Disinformation Efforts - On September 4, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) designated 10 individuals and two entities as specially designated nationals...more

Locke Lord LLP

OFAC Issues Warning to Financial ‎Institutions & Insurers That ‎Provide Maritime Services in the ‎Mediterranean, Red Sea and...

Locke Lord LLP on

Iran and Syria Sanctions and Embargos On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued updated guidance to remind maritime support service providers that the...more

Locke Lord LLP

OFAC Issues General Licenses, Updates FAQ, and Issues New Blocking Rule and Reminder to File Annual Blocked Property Report

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On September 5, 2024, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) released General License (“GL”) 108 (“Authorizing Limited Safety and Environmental Transactions Involving Certain Blocked...more

Locke Lord LLP

What Do Diamonds, Safety and the Environment Have in Common? OFAC New General Licenses and FAQs

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On August 23, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 103 ("Authorizing Transactions Related to Imports of Certain Diamond Jewelry Prohibited by...more

Locke Lord LLP

OFAC Extends and Issues General Licenses Involving Russian Tax and Civil Aviation Safety

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The U.S. Department of the Treasury’s Office of Foreign Asset Control ‎‎(“OFAC”) on (i) July 10, 2024, extended General License (“GL”) 13J (“Authorizing Certain Administrative Transactions Prohibited by Directive 4 under...more

Locke Lord LLP

OFAC Continues Restrictions Blocking ‎Enforcement of CITGO-Backed PdVSA Bonds

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An August 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) further delayed to November 12, 2024, U.S. persons’ rights as bondholders of Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5%...more

Locke Lord LLP

OFAC Releases Initiatives to Enhance ‎Public Guidance on ‎Sanctions Implementation

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On August 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a series of new initiatives to assist the public to better understand sanctions and the role of the private sector...more

Locke Lord LLP

OFAC Extends General License for GL ‎‎99A Entities and Issues New GL for VPower in Hong Kong

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On August 2, 2024, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License ("GL") 99A, which authorizes through October 12, 2024, the wind-down of transactions...more

The Volkov Law Group

U.S. Sanctions Update as of April 2024

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U.S. Persons prohibited from transactions with anyone on the OFAC SDN List without a license, regardless of country. Includes entities owned in excess of 50-percent by one or more SDNs (33-percent for select Russian...more

The Volkov Law Group

EU Revises Restrictive Measure “Best Practices” to Account for Adoption of OFAC 50% Rule Equivalent

The Volkov Law Group on

On July 3, 2024, the Council of the European Union (“EU Council”) officially promulgated a new set of best practices (“best practices” or “guidance”) for organizations seeking to comply with the latest sanctions regulations...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

The Volkov Law Group on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

The Volkov Law Group

OFAC Amends SDN and SSI List Entries to Incorporate Secondary Sanctions Warnings

The Volkov Law Group on

On July 3, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had amended entries for a multitude of entities sanctioned under the Treasury’s Russian Harmful Foreign...more

Blank Rome LLP

New Russia Sanctions Target IT Services, Enterprise Management Software, and Foreign Financial Transactions

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a significant new round of sanctions and export...more

Cadwalader, Wickersham & Taft LLP

US and UK Issue New Round of Russia-Related Sanctions in Connection with G7 Summit

During the week of the G7 Summit, both the U.S. and UK issued a new round of Russia-related sanctions as Russia’s invasion of Ukraine enters its 28th month. On June 12, 2024, the U.S. Department of the Treasury’s Office of...more

The Volkov Law Group

Is Your Sanctions Compliance Program Compliant? — A Quick Five-Question Quiz

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Checklists can be handy — by simplifying and focusing on specific issues, a checklist can organize thinking and prioritize tasks. Here are five (5) questions that are fairly simple but revealing as to whether a company’s...more

BakerHostetler

Current State of U.S. Export Controls in Response to the Russian Federation’s Invasion of Ukraine - May 2024

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In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. ...more

The Volkov Law Group

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

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Sorry to start a four-part series with a reference to music from our long-ago past.  The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks?  Well,...more

Kilpatrick

New Sanctions Measures Regarding Russia Serve as a Reminder That Failing to Comply with Sanctions and Export Controls Can Result...

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On May 1, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of State sanctioned nearly 300 individuals, businesses, and vessels abroad to further degrade Russia’s...more

Locke Lord LLP

OFAC Extends Venezuela-Related ‎General License for Limited Maintenance of Essential Operations and Wind-Down

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On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets (“OFAC”) amended General License (“GL”) 8N related to Venezuela Sanctions Regulations, 31 CFR part 591....more

Locke Lord LLP

OFAC Targets Russia’s Military-‎Industrial Base and Third-‎Country Supporters, and Issues ‎Related General Licenses

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On April 29, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published General License (“GL”) 8I related to the‎ ‎Russian Harmful Foreign Activities ‎Sanctions Regulations, 31 CFR Part...more

Locke Lord LLP

Joint U.S. – U.K. Measures Target ‎Russian Metal Exports: Prohibitions and Implications

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On December 6, 2023, and February 24, 2024, the G7 Leaders announced their intention to diminish Russia’s earnings from metal exports. On April 12, 2024, in collaboration with the United Kingdom the United States introduced...more

The Volkov Law Group

U.S. Sanctions Update - April 2024

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This handy one-pager is designed to be used by our clients to provide a quick reference guide for the complex topics of trade sanctions and export control regulations. The goal is to briefly summarize key points for each...more

The Volkov Law Group

La Oficina de Control de Activos (OFAC) no renovó la licencia 44 y en consecuencia se revoca el alivio de Sanciones a Venezuela

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El 17 de abril de 2024, la OFAC revocó formalmente el alivio de sanciones que anteriormente había proporcionado a la industria petrolera y de gas en Venezuela. Mediante la licencia 44 la OFAC había proporcionado un alivio de...more

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