While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more
5/1/2024
/ Department of Justice (DOJ) ,
Drug Trafficking ,
Economic Sanctions ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Sanction Violations ,
Statute of Limitations ,
TWEA
Key Points - On April 17, 2024, based on a determination by the U.S. government that Nicolás Maduro and his representatives “have not fully met the commitments made” with respect to upcoming Venezuelan elections, the U.S....more
Key Points -
On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took action to relax certain U.S. sanctions on Venezuela in response to the signing of an electoral roadmap...more
Introduction -
In 2022, the United States, European Union (EU) and United Kingdom, along with a significant number of other partners and allies, imposed an unprecedented number of economic, financial and trade sanctions...more
- On July 1, the Departments of Commerce, Homeland Security, State, and the Treasury issued a joint advisory on the “Risks and Considerations for Businesses with Supply Chain Exposure to Entities Engaged in Forced Labor and...more
7/10/2020
/ China ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Federal Contractors ,
Financial Institutions ,
Forced Labor ,
Human Rights ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Risk Mitigation ,
Supply Chain
- On May 14, 2020, OFAC, the Department of State and the U.S. Coast Guard jointly released guidance for persons involved in the maritime industry regarding common deceptive shipping practices used to subvert U.S. and United...more
6/4/2020
/ Economic Sanctions ,
Energy Sector ,
Enforcement Actions ,
Exports ,
Imports ,
Iran ,
Maritime Transport ,
Metals ,
New Guidance ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Shipping ,
Supply Chain ,
Syria ,
Unfair or Deceptive Trade Practices ,
Vessels
- 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
• On October 23, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed the two Turkish government ministries and three ministers that it added to its Specially Designated Nationals and...more
10/25/2019
/ Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Syria ,
Trump Administration ,
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
On September 9, 2019, the Trump administration implemented additional U.S. sanctions on Cuba by restricting personal remittances to Cuba and eliminating authorization for U.S. banks to process “U-turn” transactions involving...more
9/11/2019
/ Banking Sector ,
Cross-Border Transactions ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Foreign Policy ,
Fund Transfers ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Personal Remittance Caps ,
Trump Administration ,
U-Turn Transactions ,
U.S. Treasury
• 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
• The U.S. Department of State and the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) have imposed three new sanctions on Russia:
o Effective August 26, 2019, U.S. banks (as defined below) are...more
8/14/2019
/ Biological-Weapons ,
CBW Act ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Financial Institutions (FFI) ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sovereign Debt ,
Trump Administration
• On June 21, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued and put into effect an Interim Final Rule (Interim Rule) that requires all U.S. persons and persons subject to U.S....more
• President Trump issued a new Executive Order (EO) on May 8, 2019—exactly one year after the Trump administration withdrew from the Iran nuclear deal—that widened the scope of existing sanctions targeting the Iranian...more
6/4/2019
/ Aluminum Sales ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Steel Industry ,
Trump Administration
• Yesterday, May 2, the United States government allowed implementation of Title III of the Helms-Burton Act, for the first time since the law was enacted in 1996, to permit U.S. nationals to sue persons that “traffic” in...more
5/3/2019
/ Banking Sector ,
Blocked Person ,
Cuba ,
Economic Sanctions ,
Financial Services Industry ,
Foreign Nationals ,
Foreign Relations ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Personal Jurisdiction ,
Risk Mitigation ,
Scope of Discovery Requests ,
Statute of Limitations ,
Trafficking ,
Travel Restrictions ,
Treble Damages ,
Trump Administration ,
U.S. Treasury ,
Visa Restrictions
In this episode, Akin Gump public law and policy senior advisor and former U.S. Rep. Ileana Ros-Lehtinen and international trade partner Nnedi Ifudu discuss U.S. sanctions on Venezuela.
Among the topics covered:
• the...more
4/24/2019
/ Banking Sector ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Member State ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Steel Industry ,
Trump Administration ,
Venezuela ,
WTO
• OFAC recently added a Moscow-based Russian-Venezuelan joint venture bank, Evrofinance Mosnarbank (“Evrofinance”), to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) for engaging in sanctions...more
3/29/2019
/ Banking Sector ,
Blocked Person ,
Economic Sanctions ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Joint Venture ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Trump Administration ,
Venezuela
• 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
• On November 28, 2018, OFAC designated two Iran-based individuals who helped exchange cryptocurrency (bitcoin) into fiat currency on behalf of alleged ransomware perpetrators who targeted U.S. businesses and municipal...more
1/11/2019
/ Bitcoin ,
Blocked Person ,
Corporate Counsel ,
Crypto Exchanges ,
Cryptocurrency ,
Cyber Attacks ,
Cyber Crimes ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Digital Currency ,
Digital Wallets ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
SDN List ,
U.S. Treasury
• 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
• 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
11/27/2018
/ Aircraft ,
Blocking Statutes ,
Cross-Border Transactions ,
Economic Sanctions ,
EU ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Humanitarian Assistance ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
SDN List ,
Special Purpose Vehicles ,
SWIFT ,
Trade Policy ,
Trump Administration ,
Vessels
• On October 11, 2018, FinCEN released an advisory to help U.S. financial institutions better detect potentially illicit transactions related to Iran.
• The advisory describes how Iran attempts to access the international...more
10/23/2018
/ Advisory Opinions ,
AML/CFT ,
Banks ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
International Finance ,
International Relations ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
Money Services Business ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SDN List ,
Virtual Currency
• On September 20, 2018, for the first time, the Trump administration imposed sanctions on a non-U.S. entity and its director for engaging in “significant transactions” with a Russian defense sector company included on the...more
9/26/2018
/ Blocked Person ,
CAATSA ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Intelligence Services ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Secondary Sanctions ,
Suppliers ,
Trump Administration
• 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
• On May 22, 2018, OFAC issued General License 15, authorizing U.S. persons to engage in specified transactions related to maintenance or wind-down of operations, contracts or other agreements involving GAZ Group or any...more