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California Moves to Regulate Digital Asset Exchanges and Cryptocurrency Companies

California's new Digital Financial Asset Law ("DFAL") will impose a variety of regulatory requirements on digital asset companies and cryptocurrency exchanges. Governor Newsom is expected to sign the DFAL into law, and new...more

OFAC Issues Additional Ransomware Guidance and Designates Virtual Currency Exchange

The U.S. Treasury Department has issued an updated ransomware advisory that highlights sanctions risks associated with ransomware payments and details proactive steps companies can take to mitigate these risks....more

United States Imposes New Sanctions on Russia

The Situation: On April 15, 2021, the United States issued a new executive order and related directive imposing additional sanctions on Russia that target dealings in Russian sovereign debt, the technology and defense sectors...more

Biden Administration Imposes Sanctions on Burma Following Military Coup

As part of the U.S. government response, the Department of the Treasury imposes sanctions on certain Burmese persons, and the Department of Commerce heightens export restrictions relating to Burma. In response to the...more

U.S. Treasury Sanctions Senior Hong Kong Officials Under Authority of Executive Order on Hong Kong Normalization

The Situation: On August 7, 2020, the U.S. Department of the Treasury ("Treasury Department") took the first action under the authority of "The President's Executive Order on Hong Kong Normalization" ("HK Normalization EO")...more

Court Vacates $2 Million OFAC Penalty Against Exxon, Citing Lack of Fair Notice

The Situation: A U.S. District Court vacated a $2 million penalty imposed by the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") against Exxon Mobil Corporation ("Exxon") because OFAC failed to...more

New Sanctions Target Additional Sectors of Iranian Economy

The Situation: The Trump administration announced a new round of sanctions on January 10, 2020, following escalating tensions between the United States and Iran. The Result: The new sanctions complement existing sanctions...more

U.S. Imposes Sanctions on Turkish Officials, Ministries in Response to Syrian Offensive

The Situation: In response to events in Syria and in the face of strong Congressional pressure to act, President Trump introduced sanctions targeting Turkey. The Result: Although the President indicated that a ceasefire...more

President Trump Expands Sanctions Targeting Maduro Regime - "Embargo" order blocks property of Government of Venezuela and...

On August 5, 2019, President Trump signed Executive Order 13884 ("E.O. 13884") blocking the property of the Government of Venezuela and authorizing sanctions against a range of additional persons. In connection with E.O....more

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