Each year, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) requires all holders of blocked property to submit an Annual Report of Blocked Property (“ARBP”) setting forth all blocked...more
The supplemental appropriations legislation signed into law on April 24, 2024 enacted numerous high-profile provisions addressing aspects of U.S. foreign policy and national security, including provisions that broaden and...more
7/26/2024
/ Compliance ,
Economic Sanctions ,
Financial Services Industry ,
Foreign Policy ,
Interim Final Rules (IFR) ,
International Emergency Economic Powers Act (IEEPA) ,
Liquidation ,
National Security ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Reporting Requirements ,
Russia ,
TWEA ,
Ukraine
On June 12, 2024, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), in coordination with the U.S. Department of State, announced a new wave of Russia sanctions that significantly expand...more
2024 has already been a busy year for sanctions on Russia, with the implementation of new sanctions and intensifying enforcement of existing sanctions authorities, with no signs of slowing down....more
On February 8, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the imposition of sanctions against a network of foreign entities and a vessel involved in an asserted price cap...more
The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more
1/26/2024
/ AML/CFT ,
Audits ,
Civil Monetary Penalty ,
Compliance ,
Criminal Penalties ,
Crude Oil ,
Cryptocurrency ,
Due Diligence ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
International Emergency Economic Powers Act (IEEPA) ,
Liability ,
Maritime Transport ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Risk Assessment ,
Sanction Violations
On January 18, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the imposition of sanctions against a United Arab Emirates-based shipping company, Hennesea Holdings Limited (“Hennesea”)...more
The nation’s first large-scale offshore wind farm started spinning its blades on January 2nd. The wind project, known as Vineyard Wind 1, began operations near Martha’s Vineyard 15 miles off the coast of Massachusetts,...more
On December 12, 2023, the Department of Justice (DOJ), Department of Commerce’s Bureau of Industry and Security (BIS), Department of Homeland Security’s Homeland Security Investigations (HSI), the Department of State’s...more
Background:
On Friday November 29, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Sinbad.io (“Sinbad”), alleging that the virtual currency mixer serves as a key money-laundering...more
On December 1, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets control (OFAC) announced the imposition of sanctions on three entities and identified as blocked property three vessels that used Price Cap...more
On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) eased certain sanctions on the oil and gas sector, as well as the gold sector, in Venezuela, following the announcement of a...more
On October 12, 2023, OFAC released an Advisory for the Maritime Oil Industry and Related Sectors: Best Practices in Response to Recent Developments in the Maritime Oil Trade on behalf of the G7, European Union and Australia...more
In a recent decision filed August 2, 2023 in the Supreme Court of the Republic of the Marshall Islands (the RMI) Seward & Kissel LLP secured victory for its client, Sea Justice Ltd., in the action styled Symphony Shipholding...more
Summary of the Recent SEC Actions -
On August 8, 2023, in yet another set of enforcement actions in the space, the U.S. Securities and Exchange Commission (the “SEC”) settled charges against ten broker-dealers and a dually...more
On August 9, 2023, President Biden issued Executive Order 14105 “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern.” The Executive Order targets certain U.S....more
8/18/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Artificial Intelligence ,
China ,
ETFs ,
Executive Orders ,
Foreign Investment ,
Hong Kong ,
Investment ,
Joe Biden ,
Macau ,
National Security ,
Notification Requirements ,
Outbound Transactions ,
Penalties ,
Rulemaking Process ,
Semiconductors ,
Technology Sector ,
U.S. Treasury
The ascending importance of rigorous and compliance with U.S. national security laws, including sanctions and export controls, was underscored on July 26, 2023 with the release of a Department of Commerce, Department of the...more
8/2/2023
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Export Controls ,
FinCEN ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements
To paraphrase what Ben Franklin may have been alluding to nearly 300 years ago in his famous quote, often the best approach when it comes to reducing the risk of litigation and government enforcement proceedings is to take...more
7/27/2023
/ Anti-Corruption ,
Anti-Discrimination Policies ,
Anti-Harassment Policies ,
Anti-Money Laundering ,
California Consumer Privacy Act (CCPA) ,
Compliance ,
Data Privacy ,
Data Security ,
Document Review ,
Due Diligence ,
Employment Contract ,
Enforcement ,
Ethics ,
Force Majeure Clause ,
Fraud ,
General Data Protection Regulation (GDPR) ,
Health and Safety ,
Insurance Industry ,
Intellectual Property Protection ,
Investigations ,
Non-Public Information ,
Performance Reviews ,
Personal Information ,
Pricing ,
Reporting Requirements ,
Risk Mitigation ,
Sales ,
Social Media ,
Technology Sector
Background -
The Ocean Shipping Reform Act (OSRA), which amends the Shipping Act, was signed into law by U.S. President Joseph Biden in 2022 to alleviate certain measures taken by shipping companies in the midst of supply...more
On May 19, 2023 the United States, in coordination with the G7 and other international partners, imposed more than three-hundred new sanctions on Russia for its war in Ukraine. Press releases providing additional information...more
Reports of supply chain litigation from troubled retailer Bed Bath & Beyond (BBBY) before the Federal Maritime Commission (FMC) have hit the news, reflecting a trend of increasing supply chain litigation before the FMC since...more
On April 17, 2023, the United States Treasury Department’s Office of Foreign Assets Control (OFAC) issued an alert warning U.S. persons about possible evasion of the price cap on Russian Federation origin crude oil,...more
Shipping companies should remain focused on sanctions compliance for 2023. The sanctions space has been bursting with activity as a result of the Russia-Ukraine war, which shows no signs of abating. Companies continue to seek...more
4/7/2023
/ Civil Monetary Penalty ,
Economic Sanctions ,
Enforcement Actions ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Oversight ,
Russia ,
Sanction Violations ,
Shipping ,
Transportation Industry ,
U.S. Treasury
On February 24, 2023, the one-year anniversary of Russia’s invasion of Ukraine, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the imposition of additional sanctions targeting multiple...more
As noted in our prior alerts (concerning OFAC’s September 9, 2022 preliminary guidance, an October 31, 2022 follow-on FAQ clarifying the applicability of the price cap policy, and the December 5, 2022 effective date of the...more