Johann Strauss on Office of Foreign Assets Control (OFAC)

U.S. Government Imposes Expansive, Novel and Plurilateral Export Controls Against Russia and Belarus

Key Points - As part of highly coordinated U.S. government and allied and partner country responses to Russia’s further invasion of Ukraine, and Belarus’ enabling of it, BIS imposed on February 24, 2022, and March 2,...more

3/10/2022 / Belarus , Belarus Sanctions , Bureau of Industry and Security (BIS) , Economic Sanctions , Export Administration Regulations (EAR) , Export Controls , Military End Use , Office of Foreign Assets Control (OFAC) , Russia , Ukraine

Treasury to Companies: Time to Take Ransomware Reporting Seriously

On September 21, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an updated sanctions advisory, providing guidance to companies on sanctions compliance obligations related to ransomware...more

12/14/2021 / Compliance , Cryptocurrency , Cyber Attacks , Cybersecurity , Data Security , New Guidance , Office of Foreign Assets Control (OFAC) , Ransomware , Sanctions , U.S. Treasury , Virtual Currency

Treasury Publishes U.S. Sanctions Policy Review and Framework for Future Action

On October 18, 2021, the U.S. Treasury Department released a long awaited report on its first of its kind “top to bottom” review of U.S. economic and financial sanctions. The report does not make or recommend any immediate or...more

11/1/2021 / Cryptocurrency , Cybersecurity , Export Controls , Exports , National Security , Office of Foreign Assets Control (OFAC) , Sanctions , U.S. Treasury , Virtual Currency

International Trade Impacts of The Coronavirus: Update On Government And Industry Actions And Key Considerations For Trade...

The new coronavirus, SARS-CoV-2, and the disease it causes, COVID-19, have created diverse, complex, and immediate challenges for world governments, multinational businesses, and other international institutions and projects....more

3/10/2020 / Airports , Coronavirus/COVID-19 , Economic Sanctions , Exports , Federal Funding , Health and Safety , Imports , Infectious Diseases , Manufacturers , Medical Supplies , Multinationals , New Guidance , Office of Foreign Assets Control (OFAC) , Public Health , Risk Assessment , Supply Chain , Trade Relations , Travel Restrictions , Travelers

OFAC Sanctions Key Rosneft Subsidiary and Executive for Operating in the Oil Sector of Venezuela

- On February 18, 2020, OFAC designated Rosneft Trading, S.A. (Rosneft Trading), a subsidiary of Russia-based Open Joint-Stock Company Rosneft Oil Company (Rosneft Oil Company), and its president, Didier Casimiro, on the SDN...more

2/21/2020 / Blocked Person , Crude Oil , Economic Sanctions , Energy Sector , Export Controls , Exports , General Licenses , Office of Foreign Assets Control (OFAC) , Oil & Gas , SDN List , Venezuela

U.S. Government Authorizes Economic Sanctions on Turkey

• A new Executive Order signed October 14, 2019, authorizes U.S. sanctions related to the military conflict between Turkey and Syria, providing broad authority to impose sanctions against Turkish government agencies,...more

10/17/2019 / Blocked Person , Economic Sanctions , Executive Orders , Foreign Policy , Foreign Relations , General Licenses , Office of Foreign Assets Control (OFAC) , SDN List , Trump Administration , Turkey

Trump Administration Imposes Broad Sanctions on the Government of Venezuela

• In a further escalation of U.S. sanctions on Venezuela in support of its efforts to oust the regime of Nicolás Maduro, on August 5, 2019, the Trump administration imposed comprehensive sanctions on the Government of...more

8/19/2019 / Banking Sector , Blocked Entities , Blocked Person , Economic Sanctions , Executive Orders , Financial Institutions , Foreign Policy , Foreign Relations , General Licenses , Office of Foreign Assets Control (OFAC) , SDN List , Trump Administration , Venezuela

Legal and Practical Considerations of the Trump Administration’s Designation of the IRGC as a Foreign Terrorist Organization

• On April 8, 2019, the U.S. government announced its intention to designate the Islamic Revolutionary Guards Corps (IRGC) as a Foreign Terrorist Organization, effective April 15, 2019. This unprecedented action will result...more

4/15/2019 / Antiterrorism and Effective Death Penalty Act (AEDPA) , CAATSA , Foreign Policy , Iran , Iran Sanctions , National Security , Office of Foreign Assets Control (OFAC) , SDN List , Terrorist Threats , Trump Administration , U.S. Treasury

OFAC Sanctions Venezuelan State-Owned Energy Company PdVSA, Releases New General Licenses and FAQs for Venezuela Sanctions Regime

• On January 28, 2019, OFAC added the Venezuelan state-owned oil and natural gas company PdVSA to its SDN List. • As a result, U.S. persons are generally prohibited from engaging in transactions with PdVSA and entities that...more

2/6/2019 / Blocked Person , Bonds , Capital Markets , Debt-Equity , Economic Sanctions , Energy Sector , Executive Orders , General Licenses , Office of Foreign Assets Control (OFAC) , Oil & Gas , SDN List , Securities Transactions , State-Owned Enterprises , Trump Administration , Venezuela

New U.S. Sanctions Regime Targeting Nicaragua

• On November 27, 2018, the Trump administration issued an executive order establishing a new sanctions regime against Nicaragua. • This occurs as the Trump Administration has articulated an approach to Latin America in...more

12/4/2018 / Blocked Person , Economic Sanctions , Executive Orders , Human Rights , National Security , Nicaragua , Office of Foreign Assets Control (OFAC) , Public Officials , SDN List , Trump Administration

Iran Sanctions Are Here—Breaking Down What This Means For Business

• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more

President Trump Issues New Iran Executive Order and Reimposes First Set of Sanctions Following JCPOA Withdrawal

• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more

8/17/2018 / Blocking Statutes , Economic Sanctions , EU , Executive Orders , International Relations , Iran , Iran Sanctions , Joint Comprehensive Plan of Action (JCPOA) , Office of Foreign Assets Control (OFAC) , SDN List , Secondary Sanctions , Trade Relations , Trump Administration , Winding Down , Withdrawal

United States Imposes New Sanctions Restricting Transactions with the Government of Venezuela

• On May 21, 2018, the Trump administration imposed new sanctions on the Government of Venezuela in response to the reelection of President Maduro and the “deepening humanitarian and public health crisis” fueled by the Maduro...more

5/24/2018 / Debt-Equity , Economic Sanctions , Executive Orders , Financial Institutions , Foreign Policy , Office of Foreign Assets Control (OFAC) , Securities Transactions , Trump Administration , Venezuela

President Trump Announces U.S. Withdrawal from JCPOA; U.S. Sanctions on Iran will be Re-imposed Following Wind-Down Periods

• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more

5/10/2018 / Controlled Foreign Corporations , Economic Sanctions , Exports , Foreign Financial Institutions (FFI) , Foreign Policy , Foreign Relations , General Licenses , Iran , Iran Sanctions , Joint Comprehensive Plan of Action (JCPOA) , Office of Foreign Assets Control (OFAC) , SDN List , Trade Policy , Trump Administration

Iran: President Trump Gives the Iran Nuclear Deal a “Last Chance” While Pressuring European Allies to Act

On January 12, 2018, the U.S. administration took three actions relating to Iran - • First, President Trump waived again the application of certain nuclear sanctions while making clear that the United States will refuse to...more

2/1/2018 / Anti-Terrorism Financing , Economic Sanctions , Iran , Iran Nuclear Agreement Review Act of 2015 (INARA) , Iran Sanctions , Joint Comprehensive Plan of Action (JCPOA) , Nuclear Weapons , Office of Foreign Assets Control (OFAC) , Trump Administration

Iran: Following President Trump’s “Decertification,” New U.S. Sanctions on Iranian Entities and All Eyes on the U.S. Congress

• Effective October 13, 2017, President Trump declined to provide certification that the JCPOA is in the United States’ national interest. Following this “decertification,” the U.S. Congress has 60 days in which to introduce...more

11/2/2017 / Anti-Terrorism Financing , Decertify , Economic Sanctions , Executive Orders , Foreign Policy , Foreign Relations , Iran , Iran Nuclear Agreement Review Act of 2015 (INARA) , Iran Sanctions , Joint Comprehensive Plan of Action (JCPOA) , Legislative Amendments , Members of Congress , Nuclear Weapons , Office of Foreign Assets Control (OFAC) , Proposed Legislation , SDN List , Sunset Provisions , Trump Administration , U.S. Treasury

Trump Administration Lifts U.S. Sanctions on Sudan; Important Limitations Remain

Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more

10/13/2017 / Bureau of Industry and Security (BIS) , Commerce Control List , Commodities , Department of Defense (DOD) , Economic Sanctions , Executive Orders , Export Administration Regulations (EAR) , Exports , General Licenses , Office of Foreign Assets Control (OFAC) , SDN List , Secretary of State , Sudan , Trade Restrictions , Trump Administration , TSRA

Johann Strauss

Akin Gump Strauss Hauer & Feld LLP

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