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Sanctions U.S. Treasury

A&O Shearman

US imposes new sanctions and export controls against Russia

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On June 12, 2024, the U.S. Department of Treasury (Treasury), U.S. Department of State (State), and U.S. Department of Commerce (Commerce) announced another round of sanctions and export controls targeting Russia. In this...more

Brownstein Hyatt Farber Schreck

Venezuela Energy Sanctions Reimposed Barring Democratic Reforms

On April 17, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) released General License (GL) 44A, requiring the wind down of business transactions with Venezuela’s state-owned energy company Petróleos...more

A&O Shearman

U.S. sanctions enforcement in the virtual currency space - USD 1 billion and counting...

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Beginning in 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has increasingly focused its enforcement activity on entities operating in the virtual currency space, illustrating a trend that...more

Sheppard Mullin Richter & Hampton LLP

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

A&O Shearman

U.S. Imposes New Russia Sanctions and Export Controls and Warns of Risk of Continued Business with Russia

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On February 23, 2024, the United States imposed its largest number of new sanctions and export control designations against Russia to date—targeting over 600 individuals and entities across a wide swath of the Russian economy...more

A&O Shearman

OFAC Suspends Certain U.S. Sanctions Targeting Venezuela with New and Amended General Licenses

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On October 18, 2023, the United States announced the suspension of certain sanctions related to Venezuela through the issuance of new and revised general licenses. The Office of Foreign Assets Control (OFAC) of the U.S....more

Keating Muething & Klekamp PLL

Emerging State Laws Restricting Foreign Ownership of Real Estate

The Office of Foreign Assets Control (“OFAC”) is an arm of the U.S. Department of Treasury, tasked with administering and enforcing various economic and trade sanctions intended to further U.S. foreign policy and national...more

Skadden, Arps, Slate, Meagher & Flom LLP

Court Victory for Treasury and Indictment of Tornado Cash Founders Highlights AML and Sanctions Risks for DeFi Crypto Platforms

In a long-awaited decision involving the cryptocurrency “mixer” Tornado Cash, a U.S. district court on August 17, 2023, upheld the broad authority of the Department of the Treasury’s (Treasury’s) Office of Foreign Assets...more

Brownstein Hyatt Farber Schreck

U.S.-China Policy Update, July 2023 #2

Senate Adopts Outbound Investment NDAA Provision. On July 25, the Senate approved an amendment to the FY 2024 National Defense Authorization Act (NDAA) filed by Sens. John Cornyn (R-TX) and Bob Casey (D-PA) that would require...more

A&O Shearman

U.S. Cracks Down on Sanctions Evasion

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On March 2, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), the Department of the Treasury’s Office of Foreign Asset Control (OFAC) and the Department of Justice issued a joint compliance note...more

Orrick, Herrington & Sutcliffe LLP

OFAC issues extended counter-terrorism GL and amended FAQ

On January 12, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Counter Terrorism General License (GL) 21B, “Authorizing Limited Safety and Environmental Transactions Involving Certain...more

Orrick, Herrington & Sutcliffe LLP

OFAC issues and amends Iran-related FAQ

On January 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an Iran-related frequently asked question (FAQ) and amended several other Iran-related FAQs. ...more

Kohn, Kohn & Colapinto LLP

The Anti-Money Laundering Whistleblower Improvement Act: Justice for Whistleblowers; No Peace for Russian Oligarchs

A two-year campaign to create an effective law incentivizing whistleblowers to report money laundering and sanctions busting has ended with a stunning and surprise victory for whistleblowers. It started in December 2020 when...more

PilieroMazza PLLC

Weekly Update for Government Contractors and Commercial Businesses – October 2022 #4

PilieroMazza PLLC on

SBA Proposes Revisions to Ownership and Control Requirements for the 8(a) Business Development Program - As PilieroMazza noted, the Small Business Administration (SBA) released a major proposed rulemaking that will impact...more

Dechert LLP

OFAC Sanctions Virtual Currency Mixer Tornado Cash

Dechert LLP on

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on August 8, 2022, imposed sanctions against the popular decentralized virtual currency mixer Tornado Cash alleging that it has been used to launder...more

Sheppard Mullin Richter & Hampton LLP

Treasury Department Seeks to Coordinate Globally on Crypto Regulation

On July 7, 2022, the Treasury Department laid out how it would work with its overseas counterparts and in international forums as the U.S. studies cryptocurrencies to set up a possible regulatory regime. This framework is the...more

Foley Hoag LLP - Security, Privacy and the...

Federal Agencies Issue Alert Regarding Maui Ransomware

On July 7, 2022, three federal agencies – the Federal Bureau of Investigation, the Cybersecurity and Infrastructure Security Agency, and the Department of the Treasury – issued a joint alert regarding Maui Ransomware, which...more

Cranfill Sumner LLP

DOJ Announces Early Targets of Task Force KleptoCapture, Elite Anti-Money Laundering Initiative Established to Halt Russian...

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In late May, a court in the Pacific island nation of Fiji upheld on appeal the detention of the 348-foot Amadea, reportedly owned by Russian oligarch Suleiman Kerimov, whose wealth largely derives from his 76% stake in...more

Wiley Rein LLP

Treasury, Commerce Target Russia’s Tech Sector, Defense Industrial Base

Wiley Rein LLP on

On March 31, 2022, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on 21 entities and 13 individuals “as part of its crackdown on the Kremlin’s sanctions evasion networks and...more

Wilson Sonsini Goodrich & Rosati

License Exception ENC Severely Limited for Exports to Russia and Belarus, Belarus Targeted by Biden’s Third Tranche of Controls,...

The Biden administration took further action this week to degrade the ability of Belarus and Russia to sustain a military campaign against Ukraine. The measures are the latest in a series of restrictions levied by the U.S. in...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

Lowenstein Sandler LLP

Trade Matters, February 2022: A monthly newsletter covering global trade & national security developments

1. Treasury Mandates Reporting of Foreign Securities Holdings of $200M or More- All U.S. persons (custodians and end investors) who manage $200 million or more in foreign securities for themselves or others must file a...more

Wiley Rein LLP

U.S. Sanctions Individuals for ‘Destabilization Activities in Ukraine’; Is Prepared to Impose Harsher Measures

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On January 20, 2022, the U.S. Department of the Treasury’s (Treasury) Office of Foreign Assets Control (OFAC) sanctioned four individuals who are acting at the direction of the Russian Federal Security Service (FSB) to...more

Sheppard Mullin Richter & Hampton LLP

A Ruble Without a Cause: What Economic Sanctions on Russia May Mean for Your Business and Global Finance

With Russian forces massing at the Ukrainian border, the U.S. and EU have been warning of severe economic sanctions. While we wait and watch this brinksmanship play out, it is worth considering how businesses, and...more

Akin Gump Strauss Hauer & Feld LLP

Treasury to Companies: Time to Take Ransomware Reporting Seriously

On September 21, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an updated sanctions advisory, providing guidance to companies on sanctions compliance obligations related to ransomware...more

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