China has recently taken several actions showing its commitment to counter trade restrictions imposed by other countries. In March 2025, it released regulations implementing the 2021 Anti-Foreign Sanctions Law. In tandem with...more
4/14/2025
/ China ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Foreign Policy ,
Foreign Relations ,
International Trade ,
Multinationals ,
National Security ,
Regulatory Requirements ,
Trade Relations
The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more
3/3/2025
/ Anti-Money Laundering ,
Cartels ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Financial Services Industry ,
Justice Against Sponsors of Terrorism Act (JASTA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Terrorist Organizations ,
Trump Administration ,
U.S. Treasury
The United States Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control ("OFAC") exceeded the authority granted by the International Emergency Economic Powers Act ("IEEPA") when it added the...more
In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more
8/22/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Foreign Agents Registration Act (FARA) ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
As a response to the Russian invasion of Ukraine starting in late February 2022, Australia, the European Union, Japan, the United Kingdom, the United States, and many other countries have progressively imposed increasingly...more
The U.S. Treasury Department has issued an updated ransomware advisory that highlights sanctions risks associated with ransomware payments and details proactive steps companies can take to mitigate these risks....more
The Development: China's National People's Congress passed the Anti-foreign Sanctions Law (the "Anti-Sanctions Law") on June 10, 2021, which took effect immediately. The legislation was adopted by China in response to certain...more
The Situation: The EU Blocking Statute prohibits EU operators from complying with certain U.S. sanctions, creating a Catch-22 for EU operators facing two directly opposing legal regimes. Important guidance on the precise...more
The Situation: In an October 1, 2020, Advisory, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") warned that companies that make or facilitate ransomware payments to threat actors who are...more
Companies in the banking/financial, energy, logistics, and shipping sectors should assess their operations to mitigate sanctions compliance risks.
On Monday, April 22, 2019, the Trump Administration announced that, in the...more
The Situation: Using a novel approach, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") concurrently designated a non-U.S. individual to the Foreign Sanctions Evaders ("FSE") List in connection...more
The Situation: On Tuesday, May 8, 2018, President Trump announced that the United States has withdrawn from the Iran Nuclear Deal and will fully reimpose its suspended sanctions targeting Iran.
The Result: All currently...more
5/14/2018
/ Economic Sanctions ,
Exporters ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
National Security ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration ,
TSRA
On May 8, 2018, President Trump announced that the United States would cease participating in the Joint Comprehensive Plan of Action ("JCPOA"), commonly known as the Iran Deal. This will reimpose, by no later than November 5,...more
5/10/2018
/ Economic Sanctions ,
EU ,
Export Controls ,
Foreign Policy ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration
The Situation: The Trump Administration has imposed sanctions against a number of high-profile Russian individuals and entities by adding them to the Specially Designated Nationals and Blocked Persons ("SDN") List.
The...more
4/12/2018
/ Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Government Officials ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Trump Administration ,
U.S. Treasury
On Friday, October 13, 2017, President Trump announced that he would not certify that the suspension of sanctions pursuant to the Joint Comprehensive Plan of Action ("JCPOA") (commonly known as the Iran Nuclear Deal) is...more
On October 6, 2017, the United States announced that, effective October 12, 2017, it will substantially revoke sanctions on Sudan and the Government of Sudan in recognition of the Government of Sudan's sustained positive...more
In Short -
The Situation: Over the past several months, North Korea has engaged in several activities, particularly relating to missile and nuclear testing, that violate several United Nations resolutions and that...more
10/3/2017
/ Aircraft ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Accounts ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Imports ,
National Security ,
North Korea ,
Nuclear Weapons ,
SDN List ,
Secondary Sanctions ,
Third Country Entities (TCEs) ,
Trade Restrictions ,
Trump Administration ,
Vessels
On August 24, 2017, President Donald Trump issued an Executive Order imposing new sanctions intended to restrict financing connected to the Government of Venezuela. These sanctions supplement existing sanctions imposed by the...more
9/5/2017
/ Bonds ,
Citgo ,
Debt-Equity ,
Dividends ,
Economic Sanctions ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration ,
Venezuela
On August 2, 2017, President Trump signed the "Countering America's Adversaries Through Sanctions Act" ("Act") into law. The Act, which codifies and strengthens sanctions against Russia and expands sanctions against Iran and...more
8/8/2017
/ Congressional Override ,
Economic Sanctions ,
Energy Sector ,
Exports ,
Financial Services Industry ,
Foreign Relations ,
Imports ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
SSI List ,
State-Owned Enterprises ,
Trump Administration
On July 11, 2017, President Trump issued an executive order that postpones any decision regarding whether to terminate the comprehensive sanctions regime against Sudan for an additional three months—until October 12, 2017....more