U.S. Persons prohibited from transactions with anyone on the OFAC SDN List without a license, regardless of country. Includes entities owned in excess of 50-percent by one or more SDNs (33-percent for select Russian...more
8/14/2024
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
Financial Transactions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
Infrastructure ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List
This handy one-pager is designed to be used by our clients to provide a quick reference guide for the complex topics of trade sanctions and export control regulations. The goal is to briefly summarize key points for each...more
On April 22, 2024, the U.S. Department of Justice announced the indictment of 10 Venezuelan individuals for conspiring to violate the International Economic Emergency Powers Act (“IEEPA”). According to the DOJ, the...more
On April 17, 2024, OFAC formally rolled back the sanctions relief it previously provided to the Venezuelan oil and gas industry. While OFAC provided the initial relief believing that Venezuela would permit a fair and open...more
On February 28, 2024, President Biden issued a new Executive Order in order to better secure the private data of U.S. citizens from being exploited by foreign adversaries of the United States. By issuing his Executive Order...more
3/7/2024
/ Biden Administration ,
Data Brokers ,
Data Protection ,
Data Security ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Due Diligence ,
Economic Sanctions ,
Executive Orders ,
Foreign Adversaries ,
International Emergency Economic Powers Act (IEEPA) ,
Personal Data ,
Risk Management
Following the death of opposition politician Alexey Navalny, the Biden Administration announced a large swath of new and additional sanctions on the Russian Federation. The U.S. Department of Treasury’s Office of Foreign...more
2/27/2024
/ Biden Administration ,
Critical Infrastructure Sectors ,
Economic Sanctions ,
Enforcement Priorities ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Vladimir Putin
Easy come, easy go. On January 29, 2024, OFAC published General License 43A under the Venezuela Sanctions Regulations, which partially rolled back a piece of the sanctions relief it provided to the country only a few months...more
El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados Unidos tomó varias medidas para proporcionarle a Venezuela un alivio limitado a las sanciones...more
On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more
12/19/2023
/ Compliance ,
Corruption ,
Crimea ,
Crypto Exchanges ,
Cryptocurrency ,
Economic Sanctions ,
Enforcement Actions ,
Initial Coin Offering (ICOs) ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanction Violations ,
Ukraine ,
White Collar Crimes
Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de EE.UU. promulgó una serie de licencias generales al gobierno de Venezuela para brindarle un alivio al país de las sanciones económicas. La OFAC promulgó...more
11/8/2023
/ Compliance ,
Corruption ,
Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Relief Measures ,
Venezuela ,
White Collar Crimes
As we discussed previously, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently provided Venezuela with much needed sanctions relief. Specifically, OFAC issued General License 44 (among...more
11/7/2023
/ Compliance ,
Corruption ,
Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Relief Measures ,
Venezuela ,
White Collar Crimes
Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs.
About the document: ...more
11/1/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Embargo ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List
El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados Unidos tomó varias medidas para proporcionar un alivio (limitado) de sus sanciones económicas en...more
On October 18, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) took several steps to provide Venezuela with some limited relief from its sanctions. The relief includes General Licenses...more
10/23/2023
/ Compliance ,
Corruption ,
Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Relief Measures ,
Venezuela ,
White Collar Crimes
In parallel with the Office of Foreign Assets Control (“OFAC”), the Financial Crimes Enforcement Network (“FinCEN”) settled with Bittrex, Inc. (“Bittrex”), a cryptocurrency exchange that allows users to trader virtual assets,...more
10/21/2022
/ Bank Secrecy Act ,
BSA/AML ,
Crypto Exchanges ,
Economic Sanctions ,
Financial Transactions ,
FinCEN ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Settlement Agreements ,
Suspicious Activity Reports (SARs)
On October 11, 2022, the Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced settlement agreements with Bittrex, Inc. (“Bittrex”), a cryptocurrency exchange based in...more
Continuing with both its crackdown on cybercriminals and illicit digital marketplaces, along with its continued economic pressure on the Russian Federation, OFAC has sanctioned two entities that fit both criteria. On April...more
4/13/2022
/ Cryptocurrency ,
Currency Exchange ,
Cyber Crimes ,
Darknet ,
Economic Sanctions ,
Enforcement Actions ,
Military Conflict ,
Money Services Business ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Russia ,
Ukraine ,
Virtual Currency
Unsurprisingly, we’ve been fielding a significant number of inquiries regarding the latest Russian sanctions. Most companies seek black and white answers – what can we do and what can’t we do. However, sanctions are very...more
Ransomware attacks are on the rise and companies everywhere should be taking action to strengthen their cybersecurity defenses and resiliency to ensure their internal systems are able to withstand cybercrime attacks. ...more
In early October, OFAC released a guidance brochure on sanctions compliance, specifically tailored for the cryptocurrency and virtual assets industry. For seasoned compliance veterans, it ends up reading like a refresher...more
On June 21, 2019, OFAC changed its requirements for reporting on blocked or rejected transactions under 31 C.F.R. §501.604. With little fanfare, the interim rule published in the Federal Register greatly expands the...more
Sanctions law can be complex. The sanctions programs themselves are often a tangled web of do’s and don’t’s – various wind down periods, General Licenses, payment structures, and more. ...more