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Baker Botts L.L.P.

OFAC Extends Recordkeeping Requirements for All Sanctions Programs

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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

Foley & Lardner LLP

Fourth Circuit Holds No Article III Standing Where No Third-Party Viewed Inaccurate Information

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On September 11, 2024, the Fourth Circuit Court of Appeals held that there is no publication to a third party — and therefore no Article III standing under the Fair Credit Reporting Act (FCRA) — where the recipient of a...more

Dorsey & Whitney LLP

Biden Administration Again Expands Sanctions on Russia and Its Third Party Supporters

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As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...more

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2023 Trends and Lessons Learned

Today’s alert—the second in our Sanctions 2023 Year in Review Series—provides an overview of U.S. sanctions enforcement in 2023, including the key lessons learned from the public enforcement actions issued by the U.S....more

Fenwick & West LLP

U.S. Government Imposes New Export Controls and Sanctions on Russia and Belarus

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On May 19, 2023, the Biden administration announced another major round of U.S. sanctions and export controls against Russia and Belarus in response to the ongoing war in Ukraine, in coordination with the G7 Leaders’ Summit...more

Dechert LLP

English Court rules on first sanctions de-listing case under the Sanctions and Anti-Money Laundering Act 2018

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In a recent judgment, the English High Court for the first time ruled on a sanctions de-listing case under Section 38 of the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). Following the UK’s departure from the EU,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Latest EU Russian Sanctions Expand Sector Restrictions and Add Designated Individuals and Entities

On 16 December 2022, the European Union (EU) adopted a ninth package of sanctions against Russia. These impose an asset freeze on almost 200 additional individuals and entities pursuant to Council Regulation No. 269/20141...more

ArentFox Schiff

US Drops New Export Controls on the Chinese Semiconductor, Advanced Computing, and Supercomputer Industries

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On Friday, October 7, 2022, the Bureau of Industry and Security (BIS) released an interim final rule containing an enormous set of export controls that will likely damage the Chinese semiconductor, advanced computing, and...more

Wiley Rein LLP

Biden Administration Toughens Sanctions, Export Controls in Response to Continued Harmful Activities of the Russian Government

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On September 15, 2022, the Biden Administration announced a new package of sanctions and export controls to hold the Russian government accountable for its war against Ukraine. ...more

Troutman Pepper

Piecing It All Together: OFAC Combines Seven Years of Regulations, Amendments, and Interpretations All in One

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Your business was hit with a ransomware attack over the weekend, and the critical systems are locked up (i.e., encrypted). To unlock those valuable systems and continue operating the business, the threat actor demands...more

BakerHostetler

Developer Arrested Following OFAC Sanctions of the Tornado Cash Protocol

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Takeaways - ..The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued the first-ever smart contracts sanction, and its decision to sanction a nonperson may be challenged in court. ..The U.S....more

BakerHostetler

US and Foreign Companies Now Subject to Expansive US License Requirements for Business with Russia

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On February 23 and 24, 2022, the United States, through the Department of Commerce’s Bureau of Industry and Security (“BIS”) and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), took significant...more

Morrison & Foerster LLP

OFAC Year-in-Review 2021 Part II – Lessons Learned from OFAC’s 2021 Enforcement Actions

Back in July, we took a look at the enforcement actions for the first half of 2021 issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Today’s post – the second half of our OFAC 2021 Year...more

Morrison & Foerster LLP

OFAC Year in Review 2021 – Part 1

2021 was a year of transition in the United States and for the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s year, while busy, was far different from 2020, as the Biden Administration’s...more

Wiley Rein LLP

What Companies Need to Know: Uyghur Forced Labor Act Signed Into Law

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After more than a year of debate in the U.S. Congress as to the scope and enforceability, the Uyghur Forced Labor Prevention Act (UFLPA or Act) passed Congress with strong bipartisan support. President Biden has publicly...more

BCLP

OFAC to Companies: Don’t Forget Your U.S. Persons

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On September 27, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury announced a $1,423,766 settlement with Houston-based supplier, Cameron International Corporation (“Cameron”) to resolve...more

Fenwick & West LLP

Guidance for the Virtual Currency Industry; 2021 Sanctions Review Shows Increasing Focus on Digital Transactions

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On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued tailored sanctions compliance guidance for those operating in the virtual currency industry, including technology...more

Perkins Coie

OFAC Releases New Detailed Guidance for the Digital Currency Industry

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On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released guidance on sanctions compliance for the digital currency industry, the agency’s most detailed guidance to date on...more

Polsinelli

Department of the Treasury Issues New Advisory Regarding Ransomware Payments

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On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released its Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments (the “Updated Advisory”)....more

Kelley Drye & Warren LLP

OFAC Settlement with Payoneer Inc. Highlights Sanctions Expectations for Online Services

On July 23, 2021, the Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with online money transmitter Payoneer Inc. (“Payoneer” or the “company”) for processing online transactions on behalf of...more

Morrison & Foerster LLP

OFAC 2020 Year In Review

In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more

Seyfarth Shaw LLP

U. S. Supreme Court to Consider Article III Standing for Absent Class Members in Review of Ninth Circuit Decision

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The United States Supreme Court has again granted a petition to examine standing in the context of class actions, specifically whether Article III of the Constitution permits members of a certified class to recover money...more

Akin Gump Strauss Hauer & Feld LLP

Reminder Regarding the Jurisdictional Reach and Limits of U.S. Export Control, Sanctions, and Foreign Investment Regulations

United States export control, sanctions, and foreign investment (CFIUS) regulations advance U.S. national security and foreign policy interests, but in very different ways. They are also quite complex. As a result, media...more

Kelley Drye & Warren LLP

Amazon’s settlement with OFAC puts e-commerce companies on notice

Today the Office of Foreign Assets Control (OFAC) announced a settlement agreement with Amazon for apparent violations of U.S. sanctions regulations by the company. The announcement puts e-commerce and online companies on...more

The Volkov Law Group

Swiss Telecomm Company Pays $7.8 Million to Settle OFAC Sanctions Violations

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OFAC continues to aggressively enforce its sanctions programs.  In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an...more

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