Continuing the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) efforts to bolster enforcement and compliance, on April 18, 2023, BIS issued a memorandum announcing significant changes to its voluntary...more
Today’s alert—the third and final installment in our Sanctions 2022 Year in Review series—provides an overview of U.S. sanctions enforcement in 2022, including the key lessons learned from the enforcement actions issued by...more
As Russia’s war in Ukraine passes the one-year mark, and the battles on the ground move forward with escalating levels of ferocity, governments around the world continue to coordinate and respond with increasingly severe...more
3/3/2023
/ Asset Freeze ,
Bureau of Industry and Security (BIS) ,
Central Bank of Russia ,
Economic Sanctions ,
EU ,
Export Controls ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
UK ,
Ukraine
2022 was an unprecedented year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). While the sweeping new U.S. sanctions imposed against Russia and Belarus in unparalleled...more
3/2/2023
/ Burma ,
China ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
Human Rights ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
UN Security Council ,
United Nations ,
Venezuela ,
Virtual Currency
As Russia’s war in Ukraine stretches into its tenth month, governments around the world continue to coordinate and respond with increasingly severe sanctions and export controls....more
12/7/2022
/ Crude Oil ,
Economic Sanctions ,
EU ,
Export Controls ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Reporting Requirements ,
Russia ,
UK ,
Ukraine
As Russia’s bloody invasion of Ukraine nears the end of its second month, with regular reports of human rights violations, possible chemical weapons attacks, and head of state musings regarding whether this campaign amounts...more
4/18/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Markets ,
Foreign Relations ,
Japan ,
Most-Favored Nations ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Trade Relations ,
UK ,
Ukraine
As Russia’s brutal invasion of Ukraine stretches on into its second month, the United States, European Union, United Kingdom, and other global allies have continued to pour additional funding and arms into Ukraine while...more
3/23/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Funding ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SWIFT ,
UK ,
Ukraine ,
US Department of State
Back in July, we took a look at the enforcement actions for the first half of 2021 issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Today’s post – the second half of our OFAC 2021 Year...more
2/9/2022
/ Cloud Storage ,
Corporate Counsel ,
Digital Currency ,
Foreign Exchanges ,
Foreign Subsidiaries ,
Geolocation ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanctions ,
SDN List ,
U.S. Treasury ,
UK ,
Virtual Currency
2021 was a year of transition in the United States and for the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s year, while busy, was far different from 2020, as the Biden Administration’s...more
2/8/2022
/ Biden Administration ,
Burma ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Forced Labor ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Iran ,
NDAA ,
NGOs ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
U.S. Treasury
As we approach year’s end, and the pace of legislative activity ramps up, it remains critical to keep a close eye on the sanctions-related bills currently making their way, at varying speeds, through the U.S. legislative...more
11/9/2021
/ China ,
Corruption ,
Forced Labor ,
Foreign Policy ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
U.S. Treasury
On October 18, 2021, the U.S. Department of the Treasury (“Treasury”) released its 2021 Sanctions Review (“Sanctions Review” or the “Review”), which includes recommendations for preserving the effectiveness of sanctions...more
In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“DOJ” or the...more
10/15/2021
/ Cryptocurrency ,
Department of Justice (DOJ) ,
DPA ,
Enforcement Actions ,
Export Controls ,
ITAR ,
Military Service Members ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Sanctions ,
Self-Disclosure Requirements ,
United Arab Emirates (UAE) ,
US Department of State ,
Virtual Currency
In the latest turn of events in the seemingly never-ending political saga of the Nord Stream 2 pipeline, the U.S. House of Representatives (the “House”), via an amendment to the 2022 National Defense Authorization Act...more
10/7/2021
/ CAATSA ,
Foreign Entities ,
Germany ,
Joe Biden ,
National Interest Waiver ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
Sanctions ,
Trump Administration ,
US State Departments
In the Biden Administration’s latest effort to respond to the growing threat of ransomware attacks, on September 21, 2021, the U.S. Department of the Treasury (“Treasury”) announced new sanctions and ransomware guidance in an...more
As peak summer holiday season approaches, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continues to remind the private sector of the importance of strict economic sanctions compliance. OFAC...more
7/15/2021
/ Corporate Counsel ,
Department of Justice (DOJ) ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Exchanges ,
ITSR ,
Moneygram ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
U.S. Treasury
On June 3, 2021, President Biden issued a new executive order (E.O.), “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China” (E.O. 14032). The E.O. prohibits U.S....more
The legal and political skirmishing continued on both sides of the Atlantic in recent weeks over Nord Stream 2, the nearly finished Russian natural gas pipeline that continues to serve as a flash point within Europe and...more
On April 15, 2021, following discussions just days earlier of a potential summit between President Biden and Russian President Putin and as Russian troops amassed along the Ukrainian border, the Biden Administration issued...more
4/20/2021
/ Biden Administration ,
Blocked Person ,
CBW Act ,
Cybersecurity ,
Defense Sector ,
Espionage ,
Executive Orders ,
Export Controls ,
Foreign Interference in US Elections ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts ,
Technology Sector ,
Ukraine ,
Vladimir Putin
As we previously wrote in our OFAC 2020 Year in Review, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) saw a drop in enforcement activity in 2020, likely due to the massive year it had in 2019 and...more
2/18/2021
/ Audits ,
Citizenship ,
Compliance ,
Corporate Counsel ,
Enforcement Actions ,
Foreign Subsidiaries ,
Information Technology ,
Licenses ,
Nexus ,
Office of Foreign Assets Control (OFAC) ,
Remediation ,
Sanctions
In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more
2/16/2021
/ China ,
Corporate Counsel ,
Cuban Assets Control Regulations (CACR) ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Financial Institutions (FFI) ,
Iran Sanctions ,
Maritime Transport ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Pentagon ,
Pipelines ,
Popular ,
Ransomware ,
Russia ,
SDN List ,
Trump Administration
On February 11, 2021, President Biden issued Executive Order 14014 of February 10, 2021, “Blocking Property With Respect to the Situation in Burma” (“E.O. 14014”), the first sanctions-related E.O. of his new administration,...more
Former US President Trump during his term of office only a week, before the release of its 13959 No. Executive Order ( "Executive Order") has been modified . The previous executive order prohibits Americans from investing in...more
With just one week remaining in his term, President Trump amended Executive Order (“EO”) 13959, which prohibits U.S. persons from investing in the securities of Chinese Military Companies (“CMCs”), to continue his aggressive...more
On December 28, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued five new frequently asked questions (“FAQs”) that clarify the scope of Executive Order (“E.O.”) 13959, the basis for OFAC’s...more
Over the past summer, prompted by a bipartisan Congressional letter identifying a two‑decade‑old statute as an unused tool in confronting China’s strategy of “Military-Civilian Fusion,” the U.S. Department of Defense (“DOD”)...more