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Trump Reverses Course on Turkey

On October 23, 2019, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced it was removing three Turkish government ministers and two Turkish government ministries from its list of Specially Designated...more

Trump on Turkey: Sanctions on a NATO Ally Today, With Escalation or Removal Possible Tomorrow

On October 14, President Trump issued an Executive order (“E.O.”) imposing sanctions on Turkey in response to Turkey’s military offensive in northern Syria. New E.O. 13894 authorizes the U.S. Departments of State and the...more

Terrorism Sanctions Go Secondary

As part of the 18th anniversary of the September 11 attacks earlier this month, the Trump Administration effectively declared the old adage that “one person’s terrorist is another person’s freedom fighter” does not apply with...more

Back to the Future: Helms-Burton Versus the Blocking Statutes. Who Will Prevail?

Nearly a quarter century after its passage, the Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996 – commonly known as Helms-Burton, after its sponsors – was expected to revive a significant number of old disputes...more

Not Quite Cuba (Yet): OFAC Blocks The Venezuelan Government’s Property

Hot on the heels of the “Saturday Surprise,” the Trump Administration initiated “Monday Madness” earlier this week when the President issued new Executive Order (E.O.) 13884 blocking any property and interests in property of...more

TGIF? No, CBW: U.S. Government Imposes Narrow Financing Restrictions and Other Sanctions on Russia

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has a well-earned reputation in the sanctions bar for ruining weekends. The agency responsible for implementing and enforcing U.S. economic sanctions has...more

For Russia, Sanctions Are Coming

Back in February, we told you about the Defending American Security from Kremlin Aggression Act, or “DASKA,” a bipartisan effort to impose new sanctions on Russia. Interest in action against the Kremlin has only increased...more

The United States Imposes Additional Secondary Sanctions on Iran as Geopolitical Tensions Flare

With tensions rising in the Persian Gulf, and Iran on the brink of pulling out of portions of the Iran nuclear deal, President Trump issued new Executive Order 13871 last Wednesday, May 8, 2019, imposing sanctions on Iran’s...more

Sanctions Enforcement Tips from Former OFACers

Morrison & Foerster’s National Security practice provides strategic advice and counseling to clients on a broad range of challenging regulatory and compliance matters in the national security space. In advising clients, the...more

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