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Commerce, Treasury, and State Announce Measures Targeted at Further Restricting Russia and Belarus

On August 23, 2024, the U.S. Departments of Commerce, Treasury, and State published new restrictions on Russia aimed at further limiting its access to U.S. materials and international procurement networks for its military....more

OFAC Publishes Guidance on Extension of Statute of Limitations and Recordkeeping Requirements

On July 22nd, 2024, OFAC published a guidance document regarding the 21st Century Peace through Strength Act’s extension of the statute of limitations for civil and criminal violations of the International Emergency Economic...more

2nd Anniversary of Ukraine Invasion Brings New Sanctions on Russia

On February 23, 2024, on the 2nd anniversary of Russia’s invasion of Ukraine, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced significant new sanctions, adding nearly 300 Russian and select...more

White House Broadens Restrictions on Russia by Authorizing Sanctions on Foreign Financial Institutions and Expanding the Import...

On December 22, 2023, President Biden signed Executive Order 14114, titled ​“Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities” (EO 14114), with a focus on holding foreign financial...more

U.S. Temporarily Eases Sanctions Against Venezuelan Energy, Gold

On October 18, the Treasury Department’s Office of Foreign Assets Control (OFAC) eased U.S. sanctions on dealings with Venezuela’s gold and oil and gas sectors by issuing and amending several general licenses. According to...more

OFAC Issues Africa Gold Advisory

On June 27, 2023, the Treasury Department’s Office of Foreign Assets Control (“OFAC”), in conjunction with USAID, and the Departments of Commerce, Homeland Security, and Labor, published an Africa Gold Advisory identifying...more

OFAC Settlement Highlights Need for Compliance Training Across Subsidiaries for Multinational Firms

The Office of Foreign Assets Control (“OFAC”) recently announced a settlement agreement with Danfoss A/S (“Danfoss” or “the company”) in response to allegations that Danfoss directed its customers in Iran, Syria, and Sudan to...more

Summary of Sanctions Imposed on Russia This Week (March 11, 2022)

It has been almost three weeks since the U.S. and its allies began imposing serious new sanctions and export control restrictions on Russia and Belarus in response to Russia’s invasion of Ukraine. This post summarizes the...more

More Sanctions on Russia: Import Bans, Revocation of MFN Status, Luxury Goods Ban, USD Ban, Other Measures

In coordination with the European Union and G7 countries, the United States announced a raft of new sanctions and trade control measures targeting Russia today in response to the ongoing war in Ukraine. The new measures...more

Summary of Sanctions Imposed on Russia This Week (March 4, 2022)

Over the last two weeks, the United States, European Union, and allied countries imposed a broad range of sanctions and export control restrictions on Russia and Belarus in response to Russia’s invasion of Ukraine. ...more

U.S. Authorizes Broader Sanctions on Belarus, Targeting Government and Key Economic Sectors

On August 9, 2021, President Biden issued an Executive Order (E.O.) authorizing the imposition of additional sanctions on the Government of Belarus and a number of key sectors of the Belarusian economy in coordination with...more

New Executive Order Targets Investments in Chinese Surveillance and Military Companies

Today, President Biden issued an Executive Order expanding U.S. restrictions on dealings in the publicly traded securities of Chinese companies. Today’s move amends Executive Order 13959 to prohibit U.S. persons from buying...more

U.S. Treasury Lifts Sanctions on Nynas AB

On May 12, 2020, the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) announced that U.S. persons no longer need OFAC authorization to engage in dealings with Nynas AB, provided such activities do not involve blocked...more

Implications for Suppliers – Chevron Ordered to Wind Down Venezuela Business By December 1, 2020 (with Limited Wind-Down...

On April 22, 2020, President Trump ordered Chevron to “wind down” its business in Venezuela by December 1, 2020. This will have a significant impact on companies that supply Chevron with equipment used for oil and gas...more

COVID-19 – Four Key International Trade Compliance Considerations

Even as companies make rapid changes to respond to business challenges posed by the COVID-19 pandemic, executives and compliance team leaders must protect their company and employees by continuing to comply with critical U.S....more

Do Manufacturers Have to Report All Iranian Sales Inquiries to OFAC or Only Those They Have Formally Rejected? 

Treasury Issues New Guidance Regarding June 21, 2019 Amendment to the Reporting, Procedures, and Penalties Regulations (“RPPR”) - In late February, the U.S. Department of Treasury’s Office of Foreign Assets Control...more

New Sanctions on Venezuela’s National Oil Company, PDVSA

Yesterday, the Office of Foreign Assets Control (“OFAC”) listed Petroleos de Venezuela, S.A. (“PdVSA”) as a Specially Designated National (“SDN”) pursuant to its authority under Executive Order 13850. As a result of the...more

Between a Rock and a Hard Place: EU & Russia Move Forward with “Blocking Statutes” in Response to U.S. Exit from Iran Nuclear Deal

Sanctions blocking statutes being prepared by the European Commission (EC) and Russia could put companies in the middle of conflicting legal requirements, raising difficult and complex sanctions compliance decisions. ...more

The United States will Withdraw from the Iran Nuclear Deal and Fully Re-impose Nuclear Sanctions on Iran Within 180 Days

President Trump announced that the United States will exit the multilateral Iran nuclear deal and fully re-impose sanctions on Iran. After the announcement, the Office of Foreign Assets Control (OFAC), the agency responsible...more

OFAC Increases Civil Monetary Penalties

On February 10, 2017, the U.S. Treasury Department announced an increase in civil monetary penalties across a number of Treasury offices, including the Office of Foreign Assets Control (OFAC). Understanding the potential...more

Epsilon Case Highlights the Need for Sanctions Due Diligence on Resellers

As global companies begin to reenter the Iranian market, a decision issued by the U.S. District Court for the District of Columbia is an important reminder that resellers and distributors can generate liability for U.S....more

Cuba Libre?

Cuba banned all private enterprise and foreign investment following Fidel Castro's 1959 revolution. For more than 50 years, the U.S. has imposed an almost total embargo on all trade with the largest Caribbean island nation. ...more

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