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OFAC Issues Russia Sanctions General ‎Licenses and FAQs ‎Related to Securities Held at the National ‎Settlement Depository

On October 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Frequently Asked Question (“FAQ”) 1197 on securities held at the National Settlement Depository (“NSD”) in connection...more

Price Cap Coalition Issues Advisory ‎Regarding Sanctions Evasion Techniques by the Shadow ‎Fleet

On October 21, 2024, the Price Cap Coalition—comprising the G7, European Union, Australia, and New Zealand—released an updated advisory to address the rising risks of price cap evasion associated with the maritime oil trade,...more

OFAC’s Extended Recordkeeping Requirements From 5 to 10 Years

On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an Interim Final Rule amending its Reporting, Procedures, and Penalties Regulations under 31 C.F.R. Part 501. This...more

OFAC Issues Global Magnitsky ‎Sanctions Relief for Ly Young Phat Group and FAQs

On September 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 8 alongside amendments to various Frequently Asked Questions (“FAQs”) in connection with the...more

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

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

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

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

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

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

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

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

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

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

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

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

OFAC Continues Restrictions Blocking ‎Enforcement of CITGO-Backed PdVSA Bonds

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

OFAC Releases Initiatives to Enhance ‎Public Guidance on ‎Sanctions Implementation

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

OFAC Extends General License to Allow ‎Export Liquefied Petroleum ‎Gas to PdVSA for Humanitarian Aid

The Venezuela Sanctions Regulations, 31 CFR Part 591 (“VSR”), which was enacted pursuant to Executive Order (“EO”) 13850 of November 1, 2018 (“Blocking Property of Additional Persons Contributing to the Situation in...more

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

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

BIS Announces Additional Export ‎Control Restrictions Against ‎Russia and Belarus Targeting Shell ‎Companies and Business...

Effective as of June 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced several additional export control restrictions and related actions against Russia and Belarus to further...more

OFAC Limits Exports of Technology to Russia ‎‎‎and Expands Secondary Sanctions on FFIs That Support ‎Russian War ‎Efforts

On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new Determination Pursuant to Section 1 (a)(ii) of Executive Order 14071 (the “Determination”)‎ that prohibits U.S....more

OFAC Doubles Statute of Limitations ‎for Sanctions Violations

On April 24, 2024, President Biden signed into law H.R. 815 (Pub. L. 118-50), “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes” (the “Act”), which includes...more

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

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

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

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

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

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

OFAC Revokes Sanctions Suspension on Venezuela’s Oil & Gas Sector, and Extends Prohibitions to Act on PdVSA 8.5% Bonds’ CITGO...

An April 17, 2024, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) issued General License (“GL”) 44A (“Authorizing the Wind Down of Transactions Related to Oil or Gas Sector Operations in...more

OFAC Reissues Global Magnitsky ‎Sanctions Regulations

On March 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended and reissued the Global Magnitsky Sanctions Regulations (the “Regulations”) to further the Global Magnitsky Human...more

OFAC, BIS and DOJ Issue TriSeal Guidance on Obligations of Non-U.S. Persons to Comply With U.S. Sanctions and Export Control Laws

On March 5, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of Justice (“DOJ”) issued a...more

OFAC Tightens Sanctions Related to Venezuela Non-Commercial Flights

On February 29, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets (“OFAC”) amended General License (“GL”) 45B related to Venezuela Sanctions Regulations, 31 CFR part 591. Subsequently, on March 1, 2024,...more

U.S. Announces New Sanctions Against ‎Russia Following Ukraine-‎Russia War 2-Year Anniversary and ‎the Death of Aleksey Navalny

In response to the second anniversary of Russia’s illegal war against Ukraine and the death of political opposition leader and anti-corruption activist Aleksey Navalny, the United States Department of the Treasury’s Office of...more

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