On the eve of the 2024 Group of Seven (G7) Leaders’ Summit, the United States imposed new sanctions and export control measures against Russia further targeting sanctions evaders and, for the first time, the Russian...more
6/19/2024
/ Asset Seizure ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Services Industry ,
Foreign Financial Institutions (FFI) ,
Information Technology ,
Infrastructure ,
International Securities Market (ISM) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
Software ,
UK
On the second anniversary of the start of the war in Ukraine and in response to the death of activist Aleksey Navalny in a Russian prison, the United States, European Union, and United Kingdom, along with Australia and...more
3/4/2024
/ Asset Freeze ,
Australia ,
Bureau of Industry and Security (BIS) ,
Canada ,
China ,
Economic Sanctions ,
Energy Sector ,
EU ,
Export Controls ,
Financial Services Industry ,
India ,
Mining ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Transportation Industry ,
Turkey ,
UK ,
Ukraine ,
United Arab Emirates (UAE) ,
US State Departments
Throughout December, the United States, European Union, and United Kingdom adopted a series of new sanctions packages against Russia that are expansive and multilayered and pose additional compliance challenges.
The new...more
1/11/2024
/ Compliance ,
Economic Sanctions ,
EU ,
Exports ,
Financial Institutions ,
Financial Services Industry ,
Imports ,
Jurisdiction ,
Office of Foreign Assets Control (OFAC) ,
Oil Prices ,
Russia ,
SDN List ,
Software ,
U.S. Treasury ,
UK
Tornado Cash, a cryptocurrency mixer, recently suffered two major setbacks in federal regulatory efforts to block its use and prosecute its founders.
First, a federal district court threw out a lawsuit challenging the...more
9/11/2023
/ Cryptocurrency ,
Cyber Crimes ,
Decentralized Autonomous Organization (DAO) ,
Department of Justice (DOJ) ,
Foreign Entities ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Standards ,
Sanction Violations ,
SDN List ,
State Sponsors of Cyberattacks ,
U.S. Treasury
In a recent judgment, the English High Court for the first time ruled on a sanctions de-listing case under Section 38 of the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). Following the UK’s departure from the EU,...more
Since February 2022, the United States, United Kingdom, and European Union have imposed unprecedented economic sanctions on Russia and various Russian entities and individuals in response to the war in Ukraine.
Actions have...more
12/19/2022
/ Asset Freeze ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
EU ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Investment ,
Good Faith ,
Imports ,
Maritime Transport ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
Safe Harbors ,
SDN List ,
U.S. Treasury ,
UK ,
Ukraine
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on August 8, 2022, imposed sanctions against the popular decentralized virtual currency mixer Tornado Cash alleging that it has been used to launder...more
9/16/2022
/ AML/CFT ,
Blockchain ,
Cyber Crimes ,
Data Privacy ,
Decentralized Finance (DeFi) ,
Ethereum ,
Financial Transactions ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Sanctions ,
SDN List ,
State Sponsors of Cyberattacks ,
U.S. Treasury ,
Virtual Currency ,
Wire Transfers
Russia's Actions -
On February 21, 2022, Russian President Vladimir Putin signed two executive orders recognizing the DNR/LNR Regions as “sovereign and independent states.”...more
2/23/2022
/ Biden Administration ,
Blocked Person ,
Critical Infrastructure Sectors ,
Economic Sanctions ,
Enforcement Priorities ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine ,
Vladimir Putin
The United States, Russia, the North Atlantic Treaty Organization (“NATO”) and the Organization for Security and Co-operation in Europe (“OSCE”) held a series of talks this week aimed at de-escalating the situation at the...more
1/14/2022
/ CAATSA ,
Economic Sanctions ,
Financial Services Industry ,
Financial Transactions ,
Foreign Policy ,
International Relations ,
Legislative Agendas ,
NATO ,
Proposed Legislation ,
Regulatory Agenda ,
Russia ,
SDN List ,
Sovereign Debt ,
SWIFT ,
Ukraine ,
US Trade Policies
The U.S.-China trade war continues to escalate, most recently fueled by U.S. concerns over China’s assertion of increasing authority over Hong Kong. The U.S. and Chinese governments have exchanged jabs through the use of...more
7/17/2020
/ CFIUS ,
China ,
Criminal Prosecution ,
Economic Sanctions ,
Exceptions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Free Speech ,
Free Trade Agreements ,
Freedom of the Press ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Human Rights ,
Open General Export Licences (OGELs) ,
Popular ,
Revocation ,
Right to Peaceful Assembly ,
SDN List ,
Section 301 ,
Tariffs ,
Technology Sector ,
Trade Act of 1974 ,
Trade Policy ,
Trade Wars ,
Travel Ban ,
Trump Administration ,
United States
The U.S.Treasury Department’s Office of Foreign Assets Control (“OFAC”) added Rosneft Trading SA (“Rosneft Trading”), a subsidiary of Russian oil major Rosneft Oil Company (“Rosneft”), to the List of Specially Designated...more
2/25/2020
/ Crude Oil ,
Debt Instruments ,
Economic Sanctions ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Risk Assessment ,
Russia ,
Sanction Violations ,
SDN List ,
Secondary Sanctions ,
SSI List ,
U.S. Treasury ,
Venezuela ,
Winding Down
On August 5, 2019, the President signed a new executive order ( “EO 13884”) that imposes blocking sanctions on the Government of Venezuela (“GOV”). EO 13884 does not impose a trade embargo or broadly prohibit transactions...more
Last week, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), the EU Council, and Canada imposed further sanctions targeting Russian individuals and entities allegedly involved in the escalation of...more
3/22/2019
/ Australia ,
Banks ,
Blocked Entities ,
Blocked Person ,
CAATSA ,
Canada ,
CBW Act ,
Economic Sanctions ,
EU Council of Ministers ,
Executive Orders ,
Legislative Agendas ,
Liquid Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
SDN List ,
Ukraine ,
US State Departments ,
Venezuela
On February 1, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued guidance in the form of Frequently Asked Questions (“FAQs”) relating to sanctions imposed on January 28, 2019 against...more
2/4/2019
/ Blocked Person ,
Bonds ,
Derivatives ,
Due Diligence ,
Economic Sanctions ,
General Licenses ,
Non U.S. Person ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Trump Administration ,
U.S. Treasury ,
Venezuela ,
Winding Down
On January 28, 2019, the United States imposed blocking sanctions on Petróleos de Venezuela SA (“PdVSA”), the Venezuelan state-owned oil company. The measures follow President Trump’s recent decision to recognize Juan Guaidó,...more
1/31/2019
/ Blocked Person ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Financial Institutions ,
Foreign Investment ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Presidential Elections ,
SDN List ,
Trump Administration ,
Venezuela ,
Winding Down
For years, regulators around the world have struggled with whether and how to police the offering and exchange of digital assets (including virtual currencies such as Bitcoin). In the United States, such efforts were stymied...more
12/17/2018
/ Bitcoin ,
Blockchain ,
Blocked Person ,
CFTC ,
Compliance ,
Cryptocurrency ,
Digital Assets ,
Economic Sanctions ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Virtual Currency
In a long-anticipated move, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), on November 28, 2018, took direct aim at the illicit use of digital currencies by identifying two digital currency...more
On November 5, 2018, applicable wind-down periods for certain transactions with Iran ended and the second and final set of U.S. secondary sanctions that had been lifted pursuant to the Iran nuclear deal – the Joint...more
11/7/2018
/ Blocking Statutes ,
Economic Sanctions ,
Energy Sector ,
EU ,
Exports ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
SDN List ,
Secondary Sanctions ,
Shipping ,
Special Purpose Vehicles ,
Trump Administration
As expected, following his May 8, 2018, decision to withdraw the United States from the Joint Comprehensive Plan of Action (“JCPOA”), President Trump signed a new Executive Order (“E.O.”) on August 6, 2018, formally...more
8/9/2018
/ Blocking Statutes ,
EU ,
Executive Orders ,
Financial Institutions ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Winding Down ,
Withdrawal
International sanctions are a major compliance challenge for companies worldwide. The regulatory risks associated with economic sanctions, asset-freezing measures and trade embargoes are not new, but they continue to grow in...more
7/19/2018
/ Blocking Statutes ,
Bonds ,
Cryptocurrency ,
Debt Buyers ,
Debt-Equity ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
EU ,
Financial Markets ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
SDN List ,
Secondary Sanctions ,
Syria ,
Trump Administration ,
Ukraine ,
Venezuela
The Trump Administration, on April 6, 2018, imposed sanctions on a number of Russian oligarchs with vast business interests, Russian government officials, officers of Russian state-owned enterprises, and related companies....more
The U.S. government has recently been active with respect to regulating cryptocurrencies. For its part, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) recently released guidance—issued in the form of...more
4/9/2018
/ Bitcoin ,
Cryptocurrency ,
Economic Sanctions ,
ETFs ,
Executive Orders ,
Hackers ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Venezuela ,
Virtual Currency
As required under the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), the Trump Administration on Monday released an unclassified version of a report (the “Report”) identifying senior political figures and...more
1/31/2018
/ Anti-Corruption ,
Anti-Money Laundering ,
Banks ,
Blocked Entities ,
Blocked Person ,
CAATSA ,
Economic Sanctions ,
Russia ,
SDN List ,
Trump Administration ,
US State Departments
The United States announced new sanctions against the Venezuelan Government on August 25, 2017 that target the government’s ability to access U.S. debt and equity markets. The measures are intended to pressure Venezuelan...more
8/30/2017
/ Debt Instruments ,
Debt-Equity ,
Economic Sanctions ,
Executive Orders ,
Exports ,
General Licenses ,
Human Rights ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
SSI List ,
Trump Administration ,
Venezuela
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) imposed sanctions on additional Russian and Crimean persons while also issuing a general license authorizing certain transactions with a...more