The outbreak of COVID-19 is impacting international trade as global markets deal with uncertain supply and companies and governments work to ensure personal safety while developing contingency plans for handling the virus. In...more
3/12/2020
/ Breach of Contract ,
Bureau of Industry and Security (BIS) ,
Coronavirus/COVID-19 ,
Economic Sanctions ,
Export Controls ,
Exports ,
Force Majeure Clause ,
General Licenses ,
Humanitarian Assistance ,
Infectious Diseases ,
Medical Supplies ,
Multinationals ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Sanction Violations ,
Supply Chain
The U.S.Treasury Department’s Office of Foreign Assets Control (“OFAC”) added Rosneft Trading SA (“Rosneft Trading”), a subsidiary of Russian oil major Rosneft Oil Company (“Rosneft”), to the List of Specially Designated...more
2/25/2020
/ Crude Oil ,
Debt Instruments ,
Economic Sanctions ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Risk Assessment ,
Russia ,
Sanction Violations ,
SDN List ,
Secondary Sanctions ,
SSI List ,
U.S. Treasury ,
Venezuela ,
Winding Down
On August 5, 2019, the President signed a new executive order ( “EO 13884”) that imposes blocking sanctions on the Government of Venezuela (“GOV”). EO 13884 does not impose a trade embargo or broadly prohibit transactions...more
After an unusually quiet year bringing enforcement cases in 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has assumed an unprecedented pace in 2019 – since January 31, OFAC has...more
On April 25, 2019, Haverly Systems, Inc. (Haverly) agreed to pay a penalty of $75,375 to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) to settle charges related to two violations of sanctions...more
4/30/2019
/ Compliance ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Goods or Services ,
Office of Foreign Assets Control (OFAC) ,
Payment Terms ,
Penalties ,
Russia ,
Sanction Violations ,
SSI List
Last week, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), the EU Council, and Canada imposed further sanctions targeting Russian individuals and entities allegedly involved in the escalation of...more
3/22/2019
/ Australia ,
Banks ,
Blocked Entities ,
Blocked Person ,
CAATSA ,
Canada ,
CBW Act ,
Economic Sanctions ,
EU Council of Ministers ,
Executive Orders ,
Legislative Agendas ,
Liquid Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
SDN List ,
Ukraine ,
US State Departments ,
Venezuela
On February 1, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued guidance in the form of Frequently Asked Questions (“FAQs”) relating to sanctions imposed on January 28, 2019 against...more
2/4/2019
/ Blocked Person ,
Bonds ,
Derivatives ,
Due Diligence ,
Economic Sanctions ,
General Licenses ,
Non U.S. Person ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Trump Administration ,
U.S. Treasury ,
Venezuela ,
Winding Down
On January 28, 2019, the United States imposed blocking sanctions on Petróleos de Venezuela SA (“PdVSA”), the Venezuelan state-owned oil company. The measures follow President Trump’s recent decision to recognize Juan Guaidó,...more
1/31/2019
/ Blocked Person ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Financial Institutions ,
Foreign Investment ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Presidential Elections ,
SDN List ,
Trump Administration ,
Venezuela ,
Winding Down
For years, regulators around the world have struggled with whether and how to police the offering and exchange of digital assets (including virtual currencies such as Bitcoin). In the United States, such efforts were stymied...more
12/17/2018
/ Bitcoin ,
Blockchain ,
Blocked Person ,
CFTC ,
Compliance ,
Cryptocurrency ,
Digital Assets ,
Economic Sanctions ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Virtual Currency
In a long-anticipated move, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), on November 28, 2018, took direct aim at the illicit use of digital currencies by identifying two digital currency...more
On November 5, 2018, applicable wind-down periods for certain transactions with Iran ended and the second and final set of U.S. secondary sanctions that had been lifted pursuant to the Iran nuclear deal – the Joint...more
11/7/2018
/ Blocking Statutes ,
Economic Sanctions ,
Energy Sector ,
EU ,
Exports ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
SDN List ,
Secondary Sanctions ,
Shipping ,
Special Purpose Vehicles ,
Trump Administration
As expected, following his May 8, 2018, decision to withdraw the United States from the Joint Comprehensive Plan of Action (“JCPOA”), President Trump signed a new Executive Order (“E.O.”) on August 6, 2018, formally...more
8/9/2018
/ Blocking Statutes ,
EU ,
Executive Orders ,
Financial Institutions ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Winding Down ,
Withdrawal
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has tightened Iran sanctions. Specifically, OFAC revoked authorizations that (1) allowed foreign subsidiaries of U.S. companies to do business in Iran;...more
Following the U.S. decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA) and reimpose sanctions on Iran, the EU has confirmed its full commitment to keep the agreement alive for the remaining parties, as...more
6/13/2018
/ Blocking Statutes ,
EU ,
European Commission ,
Exemptions ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Waivers ,
WTO
President Trump announced today, May 8, 2018, that the United States would withdraw from the Joint Comprehensive Plan of Action (“JCPOA”), the Iran nuclear deal implemented in January 2016. In connection with the...more
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury issued updated general licenses and related guidance in connection with sanctions imposed in April on certain Russian individuals and entities...more