News & Analysis as of

Office of Foreign Assets Control (OFAC) Foreign Policy

Locke Lord LLP

OFAC Issues General Licenses, Updates FAQ, and Issues New Blocking Rule and Reminder to File Annual Blocked Property Report

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On September 5, 2024, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) released General License (“GL”) 108 (“Authorizing Limited Safety and Environmental Transactions Involving Certain Blocked...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

Locke Lord LLP

What Do Diamonds, Safety and the Environment Have in Common? OFAC New General Licenses and FAQs

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On August 23, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 103 ("Authorizing Transactions Related to Imports of Certain Diamond Jewelry Prohibited by...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024 #2

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In its continuing response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic...more

Locke Lord LLP

OFAC Extends and Issues General Licenses Involving Russian Tax and Civil Aviation Safety

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The U.S. Department of the Treasury’s Office of Foreign Asset Control ‎‎(“OFAC”) on (i) July 10, 2024, extended General License (“GL”) 13J (“Authorizing Certain Administrative Transactions Prohibited by Directive 4 under...more

Locke Lord LLP

OFAC Continues Restrictions Blocking ‎Enforcement of CITGO-Backed PdVSA Bonds

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An August 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) further delayed to November 12, 2024, U.S. persons’ rights as bondholders of Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5%...more

Locke Lord LLP

OFAC Releases Initiatives to Enhance ‎Public Guidance on ‎Sanctions Implementation

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On August 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a series of new initiatives to assist the public to better understand sanctions and the role of the private sector...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024

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In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more

Locke Lord LLP

OFAC Extends General License for GL ‎‎99A Entities and Issues New GL for VPower in Hong Kong

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On August 2, 2024, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License ("GL") 99A, which authorizes through October 12, 2024, the wind-down of transactions...more

The Volkov Law Group

U.S. Sanctions Update as of April 2024

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U.S. Persons prohibited from transactions with anyone on the OFAC SDN List without a license, regardless of country. Includes entities owned in excess of 50-percent by one or more SDNs (33-percent for select Russian...more

Locke Lord LLP

OFAC Limits Exports of Technology to Russia ‎‎‎and Expands Secondary Sanctions on FFIs That Support ‎Russian War ‎Efforts

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On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new Determination Pursuant to Section 1 (a)(ii) of Executive Order 14071 (the “Determination”)‎ that prohibits U.S....more

The Volkov Law Group

EU Revises Restrictive Measure “Best Practices” to Account for Adoption of OFAC 50% Rule Equivalent

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On July 3, 2024, the Council of the European Union (“EU Council”) officially promulgated a new set of best practices (“best practices” or “guidance”) for organizations seeking to comply with the latest sanctions regulations...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

Venable LLP

Impact of Loper Bright on International Trade Issues

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Recently, Venable's Government Division offered its general thoughts on the fallout from the Supreme Court's reversal of the long standing Chevron deference principle. Here, the International Trade and Logistics Group offers...more

Seward & Kissel LLP

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

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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

The Volkov Law Group

OFAC Amends SDN and SSI List Entries to Incorporate Secondary Sanctions Warnings

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On July 3, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had amended entries for a multitude of entities sanctioned under the Treasury’s Russian Harmful Foreign...more

Blank Rome LLP

New Russia Sanctions Target IT Services, Enterprise Management Software, and Foreign Financial Transactions

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a significant new round of sanctions and export...more

The Volkov Law Group

OFAC Settles with Mondo TV for $538k for Violation of North Korean Sanctions

The Volkov Law Group on

OFAC has been busy and not so busy — what do I mean? OFAC is administering a complex set of coordinated sanctions against Russia, in close coordination with the EU and the UK....more

Morgan Lewis

OFAC Amends the Syrian Sanctions Regulations: What’s Next?

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The US Office of Foreign Assets Control first issued the Syrian Sanctions on April 5, 2005, implementing Executive Order 13338, “Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria.” On...more

Faegre Drinker Biddle & Reath LLP

Additional Export Restrictions to Russia and Belarus: BIS Announces Additional Export Sanctions Against Russia and Belarus and...

On June 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced several significant additional export control restrictions and related actions against Russia as a response to continued...more

Holland & Knight LLP

OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

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Nearly six months after President Joe Biden signed an executive order (EO) authorizing secondary sanctions against Foreign Financial Institutions (FFIs) conducting or facilitating significant transactions with certain...more

Wilson Sonsini Goodrich & Rosati

Biden Administration Further Expands Export Controls and Sanctions on Russia and Belarus

On June 12, 2024, ahead of the 2024 G7 Summit, the Biden administration introduced new export controls and sanctions on Russia and Belarus in an effort to limit Russia’s ability to continue its war efforts against Ukraine....more

Cadwalader, Wickersham & Taft LLP

US and UK Issue New Round of Russia-Related Sanctions in Connection with G7 Summit

During the week of the G7 Summit, both the U.S. and UK issued a new round of Russia-related sanctions as Russia’s invasion of Ukraine enters its 28th month. On June 12, 2024, the U.S. Department of the Treasury’s Office of...more

The Volkov Law Group

Is Your Sanctions Compliance Program Compliant? — A Quick Five-Question Quiz

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Checklists can be handy — by simplifying and focusing on specific issues, a checklist can organize thinking and prioritize tasks. Here are five (5) questions that are fairly simple but revealing as to whether a company’s...more

Fenwick & West LLP

U.S. Imposes Sweeping New Sanctions and Export Controls on Russia and Belarus, including on Certain Software and Related Services

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Citing Russia’s “transition to a full war economy,” the United States imposed sweeping new sanctions and export controls on Russia and Belarus today, including companies and individuals that continue to supply Russia’s...more

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