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OFAC Issues New Wave of Russia Sanctions Expanding Secondary Sanctions Risk for Foreign Financial Institutions

On June 12, 2024, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), in coordination with the U.S. Department of State, announced a new wave of Russia sanctions that significantly expand...more

Full Steam Ahead on Russia Sanctions

2024 has already been a busy year for sanctions on Russia, with the implementation of new sanctions and intensifying enforcement of existing sanctions authorities, with no signs of slowing down....more

OFAC Announces New Price Cap Sanctions and Publishes Coalition Enforcement Alert

On February 8, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the imposition of sanctions against a network of foreign entities and a vessel involved in an asserted price cap...more

OFAC Sanctions UAE-Based Shipping Company and Eighteen of its Vessels in Connection with Violations of the Russian Price Cap...

On January 18, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the imposition of sanctions against a United Arab Emirates-based shipping company, Hennesea Holdings Limited (“Hennesea”)...more

“Quint-Seal” Compliance Note Highlights Intensifying U.S. Government Enforcement of Sanctions and Export Control Laws in the...

On December 12, 2023, the Department of Justice (DOJ), Department of Commerce’s Bureau of Industry and Security (BIS), Department of Homeland Security’s Homeland Security Investigations (HSI), the Department of State’s...more

OFAC Sanctions Three Vessels and their Designated Owners for Violations of the Russian Price Cap Policy

On December 1, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets control (OFAC) announced the imposition of sanctions on three entities and identified as blocked property three vessels that used Price Cap...more

DOJ Releases New Voluntary Self-Disclosure Policy

On February 22, 2023, the Department of Justice (“DOJ”) released a new voluntary self-disclosure (“VSD”) policy (available here) that applies to all United States Attorney’s Offices (“USAO”). The policy details the...more

OFAC Issues Determination and Guidance For Additional Russian Petroleum Products Price Caps

As noted in our prior alerts (concerning OFAC’s September 9, 2022 preliminary guidance, an October 31, 2022 follow-on FAQ clarifying the applicability of the price cap policy, and the December 5, 2022 effective date of the...more

OFAC Publishes Rulemaking Clarifying Longstanding “50 Percent Rule” Policy

On December 20, 2022, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it was amending its regulations in multiple sanctions programs to reflect that the property and interests in property...more

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