News & Analysis as of

SDN List

WilmerHale

Implications of EO 14157 and Recent “Foreign Terrorist Organization” and “Specially Designated Global Terrorist” Designations

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On January 20, 2025, President Donald J. Trump signed Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists” (EO 14157)....more

American Conference Institute (ACI)

Preparing for Latin American Sanctions

President Trump’s “America First Trade Policy” is creating new sanctions compliance risk for financial services institutions and companies in an area that historically has not received as much enforcement attention: drug...more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

K2 Integrity on

On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more

Troutman Pepper Locke

Financial Transactions Related to Russian Energy Now Prohibited: Expiration of OFAC ‎General License 8L

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On March 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) allowed General License (GL) 8L under the Russian Harmful Foreign Activities Sanctions Regulations to expire. As a result, broad OFAC...more

Womble Bond Dickinson

International Trade in Goods and Technology: An Ever-Changing Regulatory Landscape

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Governments have long regulated international trade in goods, technology, and investment for purposes of revenue generation, economic policy, and national security....more

The Volkov Law Group

Mitigating Risks of “Interacting” with Cartels and TCOs

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We have some new vernacular to bring into the compliance arena — companies need to address risks of interacting with cartels and transnational criminal organizations (TCOs).  Companies need to understand the laws used to...more

White & Case LLP

United States Designates Eight Cartels and Transnational Criminal Organizations

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Effective February 20, 2025, the United States Designated Eight Cartels and Transnational Criminal Organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs)....more

Troutman Pepper Locke

US Declares War on Cartels: Historic Terrorist Designations Reshape Sanctions Compliance Risks

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On February 20, 2025, the U.S. Departments of State and the Treasury designated eight Latin American drug trafficking cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), in...more

Hogan Lovells

The Instant Payment Regulation and EU restricted party screening

Hogan Lovells on

From 9 January 2025, EU payment service provides are required to shift away from transaction-based sanctions screenings for certain intra-EU instant credit payments Regulation (EU) 2024/886, the “Instant Payment Regulation”,...more

Arnall Golden Gregory LLP

OFAC and KoFIU Sanctions Compliance for Financial Technologies Companies

As financial technologies companies expand operations across borders, understanding the sanctions regimes of both the United States and South Korea becomes essential. The U.S. Treasury Department’s Office of Foreign Assets...more

Hogan Lovells

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

Hogan Lovells on

The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more

The Volkov Law Group

Haas Automation Fined $2.5 Million for Export Control and Sanctions Violations Involving China and Russia

The Volkov Law Group on

In one of the first enforcement actions of 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order against Haas Automation, Inc., a leading manufacturer of computer numerical...more

Troutman Pepper Locke

Tornado Cash Whiplash – What’s Next for Sanctions?

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We find ourselves in the midst of a raucous debate among sanctions practitioners about the impact of the Fifth Circuit’s recent decision upholding a challenge against the sanctions the Office of Foreign Assets Control (OFAC)...more

BakerHostetler

Current State of U.S. Export Controls in Response to the Russian Federation’s Invasion of Ukraine - As of January 29, 2025

BakerHostetler on

In a continued effort to hinder Russia’s ongoing invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia and Belarus. This alert...more

The Volkov Law Group

OFAC Settles with Individual for $45,179 for Violations of the Global Magnitsky Act

The Volkov Law Group on

OFAC means what it says — in more ways than one.  In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations....more

Venable LLP

Outgoing Administration Issues Sweeping Russia Energy Sector Sanctions

Venable LLP on

On January 10, 2025, the US government issued the latest round of sanctions targeting Russia’s revenue sources used to fund its war in Ukraine....more

Katten Muchin Rosenman LLP

OFAC Sanctions Russia's Energy Sector

In an effort to reduce Russian energy revenues being used to fund the war against Ukraine, on January 10, 2025, the United States Department of the Treasury's Office of Foreign Assets Control (OFAC), issued a “determination”...more

Troutman Pepper Locke

A Minefield in Russia’s Energy Sector: Biden’s Final Sanctions Act May be Game-Changing

Troutman Pepper Locke on

Days before President Biden leaves the White House, the U.S. government has delivered a major blow against Russia. On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced...more

Bracewell LLP

Biden Administration Issues Sweeping Salvo of Sanctions Against the Russian Energy Sector

Bracewell LLP on

On January 10, 2025, in a final action to, among other things, deter Russian aggression on the international stage, the US Department of the Treasury enacted sweeping new sanctions on the Russian energy sector. Specifically,...more

Kilpatrick

8 Key Takeaways | Part One -- 2024 Roundup: Key Takeaways from U.S. Sanctions Enforcement Actions and 2025 Predictions

Kilpatrick on

Throughout 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control ("OFAC") published 12 enforcement actions regarding alleged sanctions violations by foreign and domestic persons and entities....more

Fox Rothschild LLP

Investments in Chinese Technology Companies Limited by New US Outbound Investment Rule

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U.S. investors interested in investing in advanced Chinese technology companies may now be constrained by the U.S. Government’s first-ever outbound investment rule (Final Rule) which took effect on Jan. 2, 2025. The Final...more

ArentFox Schiff

OFAC Relaxes Sanctions Against Post-Assad Syria – For Now

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The US government signals careful optimism with a new general license authorizing some previously prohibited transactions, including many (but not all) transactions with Syrian governing institutions, for the next six months....more

Troutman Pepper Locke

OFAC's Latest General Licenses and FAQs Related to Russian Sanctions

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On December 18, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 1B (Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue...more

The Volkov Law Group

OFAC Designates Gazprombank for Inclusion on SDN List

The Volkov Law Group on

In a significant development underscoring the U.S. government’s continued efforts to counter Russia’s destabilizing activities, the U.S. Department of the Treasury recently announced the designation of Gazprombank as a...more

BakerHostetler

Weekly Blockchain Blog - December 2024 #3

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Digital Asset Companies Achieve Licenses, Launch Stablecoin Products - According to a recent press release, Anchorage Digital, a digital asset platform and infrastructure provider, announced that the New York State...more

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