News & Analysis as of

Office of Foreign Assets Control (OFAC) International Emergency Economic Powers Act (IEEPA) U.S. Treasury

Sheppard Mullin Richter & Hampton LLP

SoL Long to Short Limits: The Sequel — A Decade of Recordkeeping and Enforcement

On July 22, 2024, the Department of Treasury, Office of Foreign Assets Control (OFAC) announced a significant planned extension to its recordkeeping requirements, which will increase the retention period from five to ten...more

Paul Hastings LLP

Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments

Paul Hastings LLP on

Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more

Morrison & Foerster LLP

War Aid and Sanctions: National Security Act Includes Significant New Sanctions Authorities

On April 24, 2024, President Biden signed into law a long-debated $98 billion foreign aid and national security legislative package (the “Act”) providing funds for Israel, Taiwan, and Ukraine, and authorizing new sanctions...more

Mayer Brown

US Agencies’ Tri-Seal Compliance Note Emphasizes Extraterritorial Reach of Sanctions and Export Control Obligations

Mayer Brown on

On March 6, 2024, the US Departments of Commerce (“Commerce”), Treasury (“Treasury”), and Justice (“DOJ”) released their latest Tri-Seal Compliance Note (“Note”), which focuses on the “Obligations of foreign-based persons to...more

Cadwalader, Wickersham & Taft LLP

U.S. Deploys Pincer Maneuver on Perceived Crypto Abuses

Crypto’s two calling cards, decentralization and anonymity, can lead to abuses, such as money laundering and tax evasion. The U.S. Treasury has long combatted crypto money laundering...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – October 2023 Update

Bass, Berry & Sims PLC on

October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading...more

Patton Sullivan Brodehl LLP

The “DAO Jungle” Chronicles: Federal Judge Upholds Treasury Department’s Sanction of Tornado Cash for Involvement in Laundering...

In two prior posts, this blog tracked the ongoing intrigue of how the various branches of the United States government interact with blockchain and cryptocurrency organizations. We discussed the Wyoming law allowing...more

Dechert LLP

Tornado Watch: Popular Cryptocurrency Mixer “Tornado Cash” Dealt Two Major Blows in a Week

Dechert LLP on

Tornado Cash, a cryptocurrency mixer, recently suffered two major setbacks in federal regulatory efforts to block its use and prosecute its founders. First, a federal district court threw out a lawsuit challenging the...more

Ballard Spahr LLP

All Roads Lead to Roman: Alleged Tornado Cash Co-Founders Roman Storm Arrested and Roman Semenov Sanctioned, Days After Treasury...

Ballard Spahr LLP on

Complex Civil and Criminal Cases Converge - On August 17, 2023, Judge Robert Pitman of the federal district court for the Western District of Texas issued an Order granting summary judgment for the U.S. Treasury Department...more

Snell & Wilmer

Voluntary Self-Disclosures: Update on Federal Agencies’ Efforts to Incentivize Self-Reporting Violations

Snell & Wilmer on

United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more

K2 Integrity

The North Korean Crypto Threat

K2 Integrity on

Executive Summary - The North Korean threat to the crypto ecosystem is the highest form of immediate risk to the crypto-economy driven by a regime that seeks to profit from its misuse to reinforce its regime and fuel all its...more

Dechert LLP

OFAC Sanctions Virtual Currency Mixer Tornado Cash

Dechert LLP on

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on August 8, 2022, imposed sanctions against the popular decentralized virtual currency mixer Tornado Cash alleging that it has been used to launder...more

Adams and Reese LLP

The Department of Treasury Issues Guidance Regarding Sanctions Risks Inherent to Facilitating Ransomware Payments

Adams and Reese LLP on

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory outlining the risks involved with facilitating ransom payments to malicious actors conducting...more

Morrison & Foerster LLP

Trump Administration Gives Teeth To Pentagon List And Restricts U.S. Investment In Publicly Traded Securities Of Chinese Military...

Morrison & Foerster LLP on

Over the past summer, prompted by a bipartisan Congressional letter identifying a two‑decade‑old statute as an unused tool in confronting China’s strategy of “Military-Civilian Fusion,” the U.S. Department of Defense (“DOD”)...more

Morrison & Foerster LLP

OFAC Issues Advisory Highlighting Art Trade No “Goghs”

Morrison & Foerster LLP on

On October 30, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published an advisory highlighting potential sanctions risks arising from dealings in “high-value artwork” (with “particular...more

King & Spalding

Ransomware: To Pay or Not to Pay?

King & Spalding on

Ransomware has emerged as one of the most virulent cybersecurity risks, affecting public and private sector alike. In recent years, ransomware attacks have become more focused, sophisticated, costly, and numerous. Threat...more

ArentFox Schiff

US Administration Takes on Chinese Social Media

ArentFox Schiff on

President Trump signed an Executive Order (EO) (TikTok EO) August 6, 2020, banning “transactions” yet to be identified by the US Department of Commerce (Commerce) related to TikTok and its parent ByteDance Ltd. Specifically,...more

King & Spalding

Virtual Currency as a Threat to National Security?

King & Spalding on

In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd. a...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd. a...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - January 2018

ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd....more

Kelley Drye & Warren LLP

OFAC Increases Civil Monetary Penalties

On February 10, 2017, the U.S. Treasury Department announced an increase in civil monetary penalties across a number of Treasury offices, including the Office of Foreign Assets Control (OFAC). Understanding the potential...more

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