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Economic Sanctions

BCLP

Fifth Circuit Rules OFAC Cannot Sanction Tornado Cash: Loper Bright Hamstrings OFAC’s Campaign Against Crypto Laundering

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Shortly before Thanksgiving, a panel of the United States Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) did not have the authority to sanction Tornado Cash, which offers a...more

Husch Blackwell LLP

International Trade Law: 2024 Year in Review & Outlook for 2025

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Few areas will be as impacted by the incoming second Trump administration as international trade policy. Check out our team’s assessment of what the coming year may bring for trade regulation and enforcement. Husch...more

Hogan Lovells

The EU adopts 15th sanctions package against Russia and Belarus

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On 16 December 2024, the EU adopted several new sanctions measures, including its 15th package of sanctions against Russia which expands the sectoral and financial restrictions applicable to Russian persons. The EU also...more

Bracewell LLP

An "Immutable" Force Meets an Immovable Object: OFAC's Crypto Loss at the Fifth Circuit

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On November 26, 2024, the US Court of Appeals for the Fifth Circuit ruled that “immutable” smart contracts are not “property” for purposes of regulation by the US Department of the Treasury’s Office of Foreign Assets Control...more

Mayer Brown

EU Adopts 15th Sanctions Package Against Russia... And More

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As the year closes, the European Union (“EU”) continues to use sanctions as its foreign policy tool of choice. On December 16, 2024, the EU adopted a total of 15 texts providing for new sanctions. While the centerpiece, the...more

NAVEX

How CCOs Can Play a Role in Supply Chain Risk Management

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Look around the business landscape today, and supply-chain risks are everywhere –  which means that sooner or later, those risks will appear on the compliance function’s radar screen too. They probably already have....more

Locke Lord LLP

OFAC Takes Further Action Against ‎Maduro-Aligned Officials ‎Following Venezuelan Election ‎Malfeasance

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On November 27, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned 21 high-ranking Venezuelan officials aligned with Nicolás Maduro. These sanctions, issued under Executive Order...more

Hogan Lovells

Past is Prologue? DOJ Enforcement under POTUS 47

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On 21 November 2024, hot off a political comeback for the history books, president-elect Donald Trump announced former Florida attorney general Pam Bondi as his nominee for Attorney General. The announcement followed the...more

Mayer Brown

UK Weekly Sanctions Update - Week of December 9, 2024

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RUSSIA SANCTIONS - UK Government adds one individual to the UK sanctions list under the Russia regime: On December 9, 2024, OFSI added Anto Joseph to the UK sanctions list under the Russia regime.  Joseph is the CEO and...more

Carlton Fields

Transacting Insurance Business in Venezuela: Current Regulatory Challenges

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The increasingly unstable political situation in Venezuela, exacerbated by the exile of opposition candidate Edmundo González following disputed presidential election results, compels U.S. financial services companies,...more

Morrison & Foerster LLP

FARA Officials Reveal Upcoming Regulatory Changes and Enforcement Priorities for 2025

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On December 6, 2024, the U.S. Department of Justice (DOJ) provided insights into Foreign Agents Registration Act (FARA) regulatory changes and focus areas for 2025. Speaking at the American Conference Institute’s National...more

Locke Lord LLP

Between a Claim and a Hard Place: OFAC Sanctions Preempt State Insurance Laws

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U.S. sanctions laws present complex conflicts with state insurance laws. While state laws govern the timely payment of claims and other insurance practices, U.S. sanctions administered by the U.S. Department of the Treasury’s...more

WilmerHale

Post-Election Trade Strategy for Businesses: Understanding the Landscape

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President-elect Trump’s election victory has renewed the focus on international trade as a top-line concern for corporate executives. During the campaign, the president-elect expressed support for tariffs and other trade...more

Alston & Bird

Navigating Sanctions: An International Guide

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Since 2020, governments have lurched from pandemic-induced economic and health crises to new and protracted conflicts across the globe. In these times of upheaval and uncertainty, the use of sanctions has increased to an...more

Hogan Lovells

U.S. Appeals Court limits OFAC’s sanctions authority in cryptocurrency mixer case

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The Fifth Circuit held that Tornado Cash, open-source computer code known as an immutable “smart contract”, is not “property” and thus cannot be subject to blocking sanctions pursuant to IEEPA and EO 13694....more

Latham & Watkins LLP

Fifth Circuit Overturns OFAC Sanctions Against Crypto Mixer Tornado Cash

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The court ruled OFAC overstepped its authority in sanctioning Tornado Cash, holding that its smart contracts are not “property” under the governing statutes....more

Locke Lord LLP

OFAC Updates General Licenses and ‎FAQ on PdVSA 2020 8.5% ‎Bonds

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On November 7, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 5Q ("Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5...more

Paul Hastings LLP

Further Sanctions Aim to Sever Remaining Ties Between Russia and U.S. Financial System

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On November 21, 2024, the Biden Administration announced sweeping new sanctions targeting numerous Russian banks, financial institutions and officials, including one of the largest remaining unblocked Russian banks,...more

Mayer Brown

Federal Appeals Court Tosses OFAC Sanctions on Tornado Cash and Limits Federal Government’s Ability to Police Crypto Transactions

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On November 26, 2024, the United States Court of Appeals for the Fifth Circuit issued a landmark decision holding that the Treasury Department’s Office of Foreign Assets Control (“OFAC”) exceeded its statutory authority by...more

NAVEX

New Year, New Administrations, New Responses

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Global election results mean the coming years are going to be full of change for compliance. This article, from our 2025 Top 10 Trends in Risk & Compliance explores how you can prepare....more

Husch Blackwell LLP

November 2024 Trade Law Updates

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In Husch Blackwell’s November 2024 Trade Law Update you’ll learn about the following updates in international trade and supply chain law: •An update on U.S. Department of Commerce decisions - •U.S. International Trade...more

Orrick, Herrington & Sutcliffe LLP

5th Circuit reverses and remands cryptocurrency software case stating OFAC exceeded its authority

On November 26, the U.S. Court of Appeals for the Fifth Circuit reversed and remanded a decision by the district court regarding the Office of Foreign Assets Control’s (OFAC) designation of a virtual currency mixer software...more

Morgan Lewis

OFAC Signals Policy Change on Holding Conferences with Sanctioned Speakers

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Marking what appears to be a reversal of previous policy, the Office of Foreign Assets Control (OFAC) determined that US persons can, subject to certain limitations, include sanctioned persons as speakers at overseas...more

Bracewell LLP

Enforcement Trends 2025: Magic 8 Ball Says "Try Again Later"

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As the world prepares for the change of administration in January, current government officials and industry experts convened at the New York Forum on Economic Sanctions to reflect on enforcement trends in 2024, and to...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – November 2024

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You are reading the November 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. -...more

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