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
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 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
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
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
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
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
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