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Guidance to Foreign Companies on Export Controls and Sanctions: Departments of Commerce, Treasury, and Justice Issue Tri-Seal...

On Wednesday, March 6, 2024, the Department of Commerce, Department of the Treasury and Department of Justice issued another Tri-seal Compliance Note, focusing this time on the obligations of foreign based persons complying...more

Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History

On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more

OFAC Finds Digital Assets Trading Platform in Violation of Sanctions

On March 31, 2023, the Office of Foreign Assets Control (OFAC) announced a $72,230.32 settlement agreement with Uphold HQ Inc. (Uphold), a global multi-asset digital trading platform, in connection with 152 apparent...more

“Sanctions Are The New FCPA”: DOJ Increases Focus on Sanctions and Export Control Enforcement

On March 2, 2023, Deputy Attorney General Lisa Monaco delivered remarks to the ABA’s National Institute on White Collar Crime. Unsurprisingly, her remarks focused heavily on inspiring a culture of compliance – including...more

Friday Development: New Sanctions and Export Controls to Address Russia’s Ongoing Aggression in Ukraine (Including the use of...

In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more

OFAC Issues Sanctions Compliance Guidance for Instant Payment Systems

On September 30, 2022, the Office of Foreign Assets Control (OFAC) published compliance guidance for instant payment systems. The guide highlights the need for emerging payment technology companies to assess their sanctions...more

OFAC Announces Hefty Settlement with Virtual Currency Exchange / Hosted Wallet Services Provider

Settlement Agreement with Bittrex, Inc. Today, on October 11, 2022, the Office of Foreign Assets Control (OFAC) announced a $24,280,829.20 settlement agreement with Bittrex, Inc., an online virtual currency exchange and...more

Technology to Iran: OFAC Lifts Certain Iran Sanctions In Response to Protests in Iran

After Mahsa Amini was killed in the custody of “Gasht-e-Ershad” or Iran’s Guidance Patrol, commonly referred to as Iran’s morality police, following an arrest for placement of her hijab, protests have erupted throughout Iran...more

Introduction of internet-related Russia trade sanctions in the UK

On April 29, 2022, the UK introduced new measures to prevent the provision of internet services to or for the benefit of designated persons. These measures apply to the whole territory of the UK and to conduct by UK persons...more

The Crypto Enthusiast and The Regulator: What OFAC is, Could Be, and Should Be Doing to Regulate CryptoCurrencies

On May 6, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a cryptocurrency mixer, Blender.io, as a Specially Designated National (SDN). That sanction follows a series of enforcements and...more

Novel Sanctions Against Business-Related Services Connected to Russia and Additional Export Restrictions

On Sunday, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced novel and sweeping sanctions on specific categories of services in order to cripple Russia’s wartime capabilities and sanctioned key...more

Additional Import and Export Restrictions in Response to Russia’s Aggression in Ukraine

Last week, the United States government imposed additional restrictions on the imports from, and exports to, Russia. The import changes stem from the Suspending Normal Trade Relations with Russia and Belarus Act, signed into...more

U.S. and Allies Impose Additional Severe Costs on Russia for Atrocities in Ukraine (update)

Updated as of April 12, 2022 - It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed...more

U.S. and Allies Impose Additional Severe Costs on Russia for Atrocities in Ukraine

It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed forces, the United States – in...more

Crypto and Russia Sanctions: A Primer and Survival Guide For Crypto Companies

The recent comprehensive economic sanctions by the U.S. and other nations against Russia has propelled the crypto community onto the geo-political stage in a major way. As with other forms of payment and methods of money...more

Russian Risk: Transactions with Russian Banks and Exports to Russia Create Greatest Exposure Under New U.S. Ukraine-Related...

Updated as of February 25, 2022 - Key Takeaways of OFAC (Treasury) and BIS (Commerce) Actions - Major Russian Banks Blocked from the U.S. Financial System. Six major Russian banks — VEB, Promsvyazbank (PSB), VTB Bank,...more

Russian Risk: Transactions with Russian Banks and Exports to Russia Create Greatest Exposure Under New EU and UK Ukraine-Related...

Updated as of February 25, 2022 - Key Takeaways of EU and UK Recent Actions Against Russia and Ukraine Breakaway Regions - The EU adopted the first tranche of sanctions restrictions targeting financial institutions, other...more

Sanctions Compliance for Crypto: OFAC Issues Guidance Targeting Virtual Currency Industry

Last Friday, the Office of Foreign Assets Control (OFAC) published more targeted guidance for digital asset companies related to compliance with sanctions and best practices for mitigating risks. This guide comes on the heels...more

Nota Bene Podcast Episode 131: U.S. Sanctions Against Russia: Valid or Ineffective Economic Policy? with Fatema Merchant and Mario... [Audio]

U.S.-Russia relations have been complicated, to say the least. Given Russia’s recent cyberattacks on SolarWinds and the government-directed attempts to influence the 2020 U.S. presidential election, the Biden administration...more

Russia Russia Russia! The Biden Administration Imposes Tough Sanctions on Russia

This week has been a week of significant foreign policy action. Today, President Biden issued a new Executive Order imposing tough sanctions on Russia for its interference in the U.S. 2020 presidential election, as well as...more

New Year Sanctions Roundup: Where Do We Stand?

Happy new year everyone. The government is shut down, but there has already been a flurry of activity in 2019 on the economic sanctions and embargoes front. Here is a summary of where we stand on various sanctions regimes....more

Digital Cops and Cyber Robbers: OFAC Guidance on Crypto Currency

A lot of us in the sanctions compliance world were wondering whether and when OFAC would issue official guidance on its application of sanctions in the digital currency world. On March 18, OFAC issued five FAQs related to...more

Movements Without Motion In Russian Sanctions Policy

Since the U.S. government determined that Russia interfered in the 2016 election, movement around Russia sanctions policy has been vigorous, if not unidirectional. Twice in 2016, the United States implemented sanctions...more

2/12/2018  /  CAATSA , Economic Sanctions , Russia

Could the Crypto-Rouble Spell Crypto-Trouble for Sanctions?

Russian President Vladmir Putin has directed his government to develop a state-backed cryptocurrency, according to a Financial Times report published on January 2nd. A Putin advisor says that the “Crypto-rouble” could be used...more

Our Armchair Santería on Cuba Policy: What Will President Trump do on Cuba?

According to reports published this week, the Trump Administration is preparing to release the results of its policy review on Cuba in the “coming weeks.” We don’t have a crystal ball (or a leaking insider). But we continue...more

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