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
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 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: On April 15, 2021, the United States issued a new executive order and related directive imposing additional sanctions on Russia that target dealings in Russian sovereign debt, the technology and defense sectors...more
As part of the U.S. government response, the Department of the Treasury imposes sanctions on certain Burmese persons, and the Department of Commerce heightens export restrictions relating to Burma.
In response to the...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
The Situation: On August 7, 2020, the U.S. Department of the Treasury ("Treasury Department") took the first action under the authority of "The President's Executive Order on Hong Kong Normalization" ("HK Normalization EO")...more
The Situation: A U.S. District Court vacated a $2 million penalty imposed by the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") against Exxon Mobil Corporation ("Exxon") because OFAC failed to...more
2/20/2020
/ Due Process ,
Executive Orders ,
Exxon Mobil ,
Fair Notice ,
Fifth Amendment ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agenda ,
Sanction Violations ,
SDN List ,
Trump Administration ,
Vacated
Ambiguous, undefined terms create uncertainty and confusion, including whether owned or controlled subsidiaries of U.S. companies outside the United States are subject to this reporting requirement.
On June 21, 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 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
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