Office of Foreign Assets Control Sanctions

News & Analysis as of

The War Against Cyber Threats: President Obama Ups the Ante

Focusing on overseas cyber threats, President Obama issued an Executive Order on April 1, 2015, which grants authorization to impose sanctions on individuals and entities engaged "in malicious cyber-enabled activities that...more

Export Control Laws for the General Counsel

You are the chief legal officer of a U.S. company. Your CEO walks into your office and announces that your company is about to conclude its first international sale. In addition, the company has just appointed distributors in...more

Red Notice Newsletter - May 2015

Welcome to the May 2015 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, a German engineering firm tests Brazil's recently implemented anticorruption...more

OFAC Issues Guidance Regarding the Parameters of Authorized Travel Between the U.S. and Cuba

On May 5, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance regarding travel between the United States and Cuba. In particular, the guidance clarifies that companies authorized to...more

FinCrimes Update - April 2015 Summary, Volume 2, Issue 4

OFAC FINES PAYMENT PROCESSING COMPANY FOR PROVIDING SERVICES TO A DESIGNATED NARCOTICS TRAFFICKER - On April 15, OFAC entered into a $23,336 settlement with an Atlanta-based payment processing company for its role in...more

OFAC Publishes Guidance Regarding Travel Between U.S. and Cuba, Releases Updated FAQs Regarding Cuba-Related Sanctions

On May 5, OFAC issued new Guidance Regarding Travel Between the U.S. and Cuba, which provides information on the types of individuals and cargo that can be transported between the U.S. and Cuba by a licensed air carrier or...more

Red Notice Newsletter - April 2015

Welcome to the April 2015 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month in anticorruption developments, Canadian transportation giant faces scrutiny for alleged bribery in South...more

Sanctions Round-Up: First Quarter 2015

In this edition: - US and EU continue targeting Russia for its activity in Ukraine - Cuba-related regulatory reforms announced - P5+1 and Iran reach framework agreement - US enforcement actions:...more

New US sanctions program to combat cybercrimes: 3 action steps for tech companies

The new sanctions in President Barack Obama’s Executive Order 13694 of April 1, 2015, “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities,” target individuals and...more

Russia Bulletin - April 2015

Russia is in the midst of strategically overhauling its economy, seeking to modernize its business methods, “de-offshore” business interests and impose stricter constraints on foreign investors and multinationals operating...more

"Facilitation": A New Tool for Extraterritorial Sanctions Enforcement?

Recent OFAC and DOJ actions have focused on certain entities – overseas financial institutions – and particular conduct – US dollar clearing and associated “stripping.” The DOJ’s recent $232 million settlement and negotiated...more

President Recommends Cuba’s Removal from State Sponsors of Terrorism List

On April 14, 2015, President Obama notified Congress that he intends to remove Cuba from the State Department’s State Sponsors of Terrorism list. While this is a newsworthy occurrence, it does not have immediate, or even...more

President Issues Executive Order to Block Assets of Foreign Cyber Attackers

President Obama recently issued Executive Order 13694 (EO 13694 or EO), “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities.” EO 13694 is aimed at deterring cyber attacks,...more

Beneficial Ownership and AML, Sanctions and Anti-Corruption Compliance

Sometimes compliance realities outpace enforcement and regulatory requirements. When it comes to FinCEN’s proposal to implement a beneficial ownership rule for financial institutions, global financial institutions do not need...more

PayPal’s Settlement with OFAC Demonstrates Importance of Effective Sanctions Compliance Programs for Financial Institutions

On March 25, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement with PayPal, Inc., the money services business, to resolve apparent violations of multiple U.S. economic...more

Trade & Manufacturing - News of Note - April 2015

United States Imposes New Sanctions Against Certain Venezuelan Officials - On March, 8 President Barack Obama signed an Executive Order blocking, or "freezing," the property and interests in property of "certain...more

Schlumberger and PayPal Settlements Reinforce Breadth of Sanctions Compliance Challenges

Last week, U.S. authorities settled criminal charges against a subsidiary of Schlumberger Ltd. and civil claims against PayPal, Inc. Federal authorities alleged that these companies violated U.S. embargoes and other economic...more

"President Obama Announces New Cybersecurity Sanctions Regime"

On April 1, 2015, President Barack Obama issued an executive order (the Order) authorizing sanctions against foreign individuals or entities found to be responsible for certain malicious cyberattacks. Under the Order, the...more

Obama Executive Order Targets International Cyberattacks Against U.S. with New Sanctions

As part of a series of measures aimed at increasing preparedness and defenses against international cyberattacks on U.S. industries and government agencies, on April 1, President Obama issued Executive Order No. 13694,...more

Now's the Time to Review Your OFAC Compliance Program

Obama Executive Order Targets International Cyberattacks Against U.S. with New Sanctions - New Sanctions Are Part of U.S. Escalation of Efforts to Bolster Cyber-Security: As part of a series of measures aimed at...more

Executive Order Creates Cybersecurity Sanctions Framework

On April 1, 2015, President Obama issued an Executive Order authorizing the imposition of sanctions against designated individuals or entities found to be engaged in malicious cyber activity, including various forms of...more

How U.S. Sanctions Can Affect Companies With Russian Investors

When the White House recently announced that it was extending sanctions against Russia for another year, it cited a continued “unusual and extraordinary threat” from Russia’s activities in Ukraine. President Obama also...more

U.S. Government Announces Significant Sanctions Enforcement Actions Against Schlumberger and PayPal

The U.S. Government announced two major sanctions enforcement actions this week that reinforce the compliance challenges faced by both U.S. companies with international activities and non-U.S. companies subject to U.S....more

Inadequate Screening Processes Result in $7.65 Million Settlement for Violations of Various U.S. Sanctions Programs

On March 25, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and PayPal, Inc. (“PayPal”) agreed to a $7.65 million settlement to settle potential civil liability for 486 apparent...more

PayPal To Pay Dearly for Alleged Violations of OFAC Sanctions

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced a $7,658,300 settlement with PayPal, Inc. (PayPal) to resolve potential civil liability for 486 alleged violations of the Iranian,...more

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