Following the death of political activist Aleksey Navalny and to mark the second anniversary of Russia’s invasion of Ukraine, the United States, EU and UK adopted a series of amendments to their respective economic sanctions...more
On December 22, 2023, President Biden issued a new Russia-related Executive Order (“EO”) targeting foreign financial institutions (“FFIs”) that support Russia’s military-industrial base. The new EO allows the U.S. government...more
On May 19, 2023, the US Department of Treasury, State, and Commerce imposed the most significant tranche of sanctions and export control measures in several months. The measures included (i) new designations on the Specially...more
On 9 September 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published “Preliminary Guidance on Implementation of a Maritime Services Policy and Related Price Exception for Seaborne...more
The U.S. Government has imposed additional punitive measures against Russia in response to Russia’s actions in Ukraine. The new measures include a prohibition on imports of Russian gold into the United States, new SDN and...more
7/5/2022
/ Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Supply Chain ,
Ukraine
The Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) No. 22 on May 12, 2022, authorizing transactions that are ordinarily incident and necessary to activities that occur in specified, non-regime held...more
On February 24, 2022, the US Government imposed severe economic sanctions and export controls on Russia. The restrictions consist of two parts: 1) significant financial sanctions on a range of Russian financial institutions...more
The decision to pay millions to a cyber criminal has never been easy, but it is now even more complex. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory on September 21,...more
On 15 April 2021, the U.S. Government announced a number of new sanctions measures against Russia, targeting a variety of “harmful foreign activities” contrary to U.S. foreign policy. ...more
4/21/2021
/ Biden Administration ,
Crimea ,
Critical Infrastructure Sectors ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts
The State Department announced the imposition of sanctions on the Republic of Turkey’s Presidency of Defense Industries (“SSB”), and four related Turkish individuals under the Countering America’s Adversaries Through...more
On 19 September 2020, China's Ministry of Commerce (MOFCOM) published the Provisions on the Unreliable Entity List (Order No.4 of 2020) (provisions), which immediately came into effect. It has been over one year since MOFCOM...more
The Cuban Assets Control Regulations have been amended to prohibit U.S. persons from lodging at certain properties in Cuba, incorporate restrictions on imports of Cuban alcohol and tobacco, and revoke general licenses...more
On 14 July, the same day the president signed into law the Hong Kong Autonomy Act (the act), President Trump issued the Executive Order on Hong Kong Normalization (the EO) directing federal agencies to impose a range of trade...more
On 27 February 2020, the Office of Foreign Assets Controls (OFAC) issued General License (GL) 8 authorizing certain humanitarian trade transactions involving the Central Bank of Iran (CBI) that are otherwise prohibited under...more
3/6/2020
/ Banks ,
Commodities ,
Economic Sanctions ,
Food Supply ,
Foreign Relations ,
General Licenses ,
Global Terrorism Sanctions Regulations (GTSR) ,
Humanitarian Assistance ,
Iran ,
Iran Sanctions ,
ITSR ,
Medical Devices ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Reporting Requirements ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Switzerland ,
Trade Agreements
On 10 January 2020, in response to missile attacks by the Iranian military targeting two U.S. bases in Iraq, the United States Department of the Treasury, Office of Foreign Assets Control (OFAC) designated a number of senior...more
1/14/2020
/ Blocked Person ,
Construction Project ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Iran ,
Iran Sanctions ,
Manufacturers ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
SDN List ,
Textiles ,
Trump Administration
On 13 December 2019 the U.S. Department of Justice's (DOJ) National Security Division (NSD) announced the release of its long-anticipated and updated Export Control and Sanction Enforcement Policy for Business Organizations...more
12/19/2019
/ Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Authority ,
Export Controls ,
FCPA Guidance ,
National Security ,
Policy Statement ,
Sanction Violations ,
Self-Reporting ,
Trade Relations ,
Willful Misconduct
On 5 November 2019 the Office of Foreign Assets Control (OFAC) issued two new general licenses authorizing certain transactions involving the government of Venezuela (GOV) and certain individuals affiliated with the GOV,...more
On 14 October, President Donald Trump issued Executive Order 13894, Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria (EO).
...more
10/18/2019
/ Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Syria ,
Trump Administration ,
Turkey ,
Unauthorized Transactions
On 7 October 2019 the U.S. Department of Commerce's Bureau of Industry and Security (BIS) expanded the Entity List, restricting certain transactions with 28 Chinese entities.
...more
10/16/2019
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Doing Business ,
ECCNs ,
Economic Sanctions ,
Educational Institutions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Entities ,
Human Rights ,
Research and Development ,
Surveillance ,
Universities
On 2 August the United States announced that it will impose a second round of sanctions on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) (22 U.S.C. § 5601 et...more
On 5 August 2019 the Trump administration issued Executive Order 13884 (the executive order) imposing sweeping sanctions against the government of Venezuela, including its agencies and instrumentalities as well as any...more
On 20 June 2019 the Department of Treasury's Office of Foreign Assets Control (OFAC) issued a final interim rule (effective on 21 June 2019) amending its reporting, procedures, and penalties regulations, 31 Code of Federal...more
7/26/2019
/ Confidential Information ,
Disclosure Requirements ,
Economic Sanctions ,
Factoring Transactions ,
FOIA ,
Food Marketing Institute v Argus Leader Media ,
Interim Rule ,
License Applications ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Regulatory Oversight ,
Regulatory Requirements ,
Reporting Requirements
On 2 May 2019, the U.S. Treasury's Office of Foreign Assets Control ("OFAC"), the agency responsible for enforcing economic sanctions, published "A Framework for OFAC Compliance Commitments" (the "Framework") which outlines...more
7/3/2019
/ Cooperative Compliance Regime ,
Economic Sanctions ,
Failure to Comply ,
Foreign Policy ,
Foreign Relations ,
Framework Agreement ,
Fund Managers ,
Internal Controls ,
Investment Funds ,
Investment Management ,
Office of Foreign Assets Control (OFAC) ,
Private Equity ,
Risk Assessment ,
Sanction Violations
On 2 May 2019 the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued "A Framework for OFAC Compliance Commitments" (the framework), which outlines five components OFAC considers to be essential...more
OFAC has announced a Finding of Violation –and not a penalty–against State Street Bank and Trust Co. (SSBT) for processing 45 pension payments totaling under $12,000 on behalf of a pension plan participant who was a US...more