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Reporting Requirements Economic Sanctions Office of Foreign Assets Control (OFAC)

Locke Lord LLP

OFAC’s Extended Recordkeeping Requirements From 5 to 10 Years

Locke Lord LLP on

On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an Interim Final Rule amending its Reporting, Procedures, and Penalties Regulations under 31 C.F.R. Part 501. This...more

Foley Hoag LLP

OFAC Publishes Both Interim Final Rule Extending Recordkeeping Requirements and Comment Request Regarding its Information...

Foley Hoag LLP on

OFAC issued an interim final rule extending OFAC’s recordkeeping requirements from 5 years to 10 years, to comport with the corresponding statute of limitations extension. OFAC also published a request for public comment...more

Baker Botts L.L.P.

OFAC Extends Recordkeeping Requirements for All Sanctions Programs

Baker Botts L.L.P. on

In an era of active U.S. sanctions policy, it is not uncommon to see the Office of Foreign Assets Control (“OFAC”) issue a notice changing U.S. sanctions – promulgating a new sanctions program or updating the designation of a...more

Seward & Kissel LLP

Compliance Flash: OFAC Announces New Reporting Requirement for Financial Institutions Under the REPO for Ukrainians Act

Seward & Kissel LLP on

The supplemental appropriations legislation signed into law on April 24, 2024 enacted numerous high-profile provisions addressing aspects of U.S. foreign policy and national security, including provisions that broaden and...more

White & Case LLP

The Shadow Financial System

White & Case LLP on

The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

Hogan Lovells

OFAC issues interim final rule amending blocked property and other reporting requirements

Hogan Lovells on

The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an interim final rule set to take effect August 8, 2024, which amends the Reporting, Procedures, and Penalties Regulations (the “Regulations”)...more

Sheppard Mullin Richter & Hampton LLP

No More Postcards to OFAC in 2024: Unpacking OFAC’s New Reporting Procedures

On May 10, 2024, The Office of Foreign Assets Control (OFAC) has released a new proposed rule which would make significant changes to OFAC’s standard reporting, record-keeping, and license applications under U.S. sanction...more

Akin Gump Strauss Hauer & Feld LLP

Congress Extends Statute of Limitations for Sanctions and Certain Other National Security Programs from 5 to 10 Years and...

While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more

The Volkov Law Group

Reminder to file your 2023 Annual Report of Blocked Property: Due date September 30, 2023

The Volkov Law Group on

On September 22, 2023, the U.S. Department of Treasury Office of Foreign Assets Control (“OFAC”) issued its “Reminder to file your 2023 annual report of Blocked Property,” noting that entities or persons subject to the...more

Torres Trade Law, PLLC

Post-G7 Sanctions – Putting the G7 Leaders Voiced Concerns into Action

Torres Trade Law, PLLC on

In May 2023, the leaders of the United States, Canada, France, Germany, Italy, Japan, and the United Kingdom gathered in Hiroshima, Japan, for the annual G7 summit. The symbolic significance of these global leaders meeting in...more

Katten Muchin Rosenman LLP

OFAC Imposes New Reporting Requirement in Connection With Russia Sanctions

On May 19, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued an amendment to Directive 4 of the Russian Harmful Foreign Activities Sanctions. As originally issued on Feb. 28, 2022, in the immediate...more

Torres Trade Law, PLLC

New Anti-Money Laundering Whistleblower Law Makes Economic Sanctions Violations Reportable

To more effectively counter transnational corruption and economic sanctions evasion, recent changes to the U.S. anti-money laundering (“AML”) whistleblower regime expand and reinforce whistleblower protections and rewards in...more

Morrison & Foerster LLP

Coalition Powers Impose Russian Oil Price Cap and Outline Implementation

As Russia’s war in Ukraine stretches into its tenth month, governments around the world continue to coordinate and respond with increasingly severe sanctions and export controls....more

Venable LLP

Treasury Doubles Up Enforcement Efforts Against Noncompliant Crypto Platforms

Venable LLP on

​​​​​​​The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced yesterday that they had reached settlements for over $24 million and $29 million,...more

Eversheds Sutherland (US) LLP

Financial Crime Horizon Scanner: 2022 - Q1 (US)

Our quarterly Financial Crime Horizon Scanner for the US summarizes key financial crime related legal and regulatory changes expected over the next 2 years and provides electronic links to key resources. We hope that you...more

Eversheds Sutherland (US) LLP

FinCEN warns financial institutions to be “vigilant” for Russia sanctions violations

On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert calling on financial institutions to be “vigilant” in guarding against attempts to evade the recent imposition of expanded Russia sanctions....more

BCLP

Russia Now Focal Point of Additional Sanctions and Export Controls, With an Added Bonus for Public Companies (Oh my!)

BCLP on

In response to a variety of activities allegedly undertaken by Russia, the U.S. Government has imposed a series of additional sanctions and export control measures since early March. Collectively, the March and April...more

Hogan Lovells

U.S. government ends uncertainty surrounding the use of the Central Bank of Iran (CBI) in humanitarian trade with Iran and opens...

Hogan Lovells on

On 27 February 2020, the Office of Foreign Assets Controls (OFAC) issued General License (GL) 8 authorizing certain humanitarian trade transactions involving the Central Bank of Iran (CBI) that are otherwise prohibited under...more

Davis Wright Tremaine LLP

Deadline Approaching for Filing Newly Expanded OFAC Annual Report of Blocked Property

The September 30 deadline is fast approaching for submitting the Annual Report of Blocked Property (ARBP) to the U.S. Department of Treasury Office of Foreign Assets Control (OFAC). ...more

The Volkov Law Group

OFAC’s New §501.604 Reporting Requirement: A Small Change with a Big Impact

The Volkov Law Group on

On June 21, 2019, OFAC changed its requirements for reporting on blocked or rejected transactions under 31 C.F.R. §501.604.  With little fanfare, the interim rule published in the Federal Register greatly expands the...more

Bass, Berry & Sims PLC

Update on U.S. Sanctions: New Requirements, Continuing Enforcement

• OFAC proposes new reporting requirement for rejected transactions • Agency issues guidance on dealing with Iran • Additional parties designated under Magnitsky sanctions program • Careful diligence of...more

Hogan Lovells

OFAC update: Final interim rule amending the reporting, procedures, and penalties regulations (RPPR) and Freedom of Information...

Hogan Lovells on

On 20 June 2019 the Department of Treasury's Office of Foreign Assets Control (OFAC) issued a final interim rule (effective on 21 June 2019) amending its reporting, procedures, and penalties regulations, 31 Code of Federal...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Issues Interim Final Rule Extending Reporting Requirements for Rejected Transactions to Companies Outside the Financial...

• On June 21, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued and put into effect an Interim Final Rule (Interim Rule) that requires all U.S. persons and persons subject to U.S....more

Holland & Hart LLP

OFAC Expands Sanctions-Related Rejected Transaction Reporting Requirements

Holland & Hart LLP on

On June 21, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an interim final rule amending the Reporting, Procedures and Penalties Regulations, 31 CFR part 501 (“RPPR”). This...more

Alston & Bird

OFAC Now Requires All U.S. Companies to Report Business Rejected Due to Sanctions

Alston & Bird on

The U.S. Office of Foreign Assets Control’s expansion of reporting requirements of rejected transactions could pose a serious problem. Our International Trade & Regulatory Group uncovers the dangers and potential pitfalls to...more

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