SDN List

News & Analysis as of

Doing Business with Russia Following Sanctions: What PE Firms Need to Know

It has now been over a year since the United States and the European Union began imposing sanctions on Russian and Ukrainian individuals and entities in connection with the situation in Ukraine. The sanctions have major...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

United States Goes on the Offensive Against International Cybercrime - 2015 Cybersecurity Executive Order

On April 1, President Obama signed an Executive Order to combat the "national emergency" sparked by a rapidly evolving global cybercrime environment. The Executive Order directs the U.S. Treasury Department to impose...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

President Obama Signs New Executive Order Targeting Significant Malicious Cyber-Enabled Activities

On April 1, 2015, the Obama Administration issued an Executive Order that will sanction individuals and entities that attempt, carry out or support malicious cyber-enabled activities that pose a significant threat to U.S....more

New Executive Order Authorizes Economic Sanctions to Combat Malicious Cyber Activity

Calling cyber threats “one of the most serious economic and national security challenges to the United States” and declaring a national emergency relating to those threats, on April 1, 2015, President Obama issued an...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

President Obama Signs Executive Order Authorizing Sanctions In Response To Malicious Cyber Activity

On April 1, 2015, President Obama signed an executive order authorizing the first sanctions program to combat malicious cyber activity. The order permits the U.S. Department of the Treasury to freeze the assets of...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

President Obama Issues New Executive Order Authorizing Sanctions Against Cyber Attackers

President Obama issued an Executive Order (the “Order”) on April 1, 2015 that authorizes financial sanctions against certain “persons” (including both individuals and entities) designated by the Treasury Secretary to be...more

Cyber Sanctions and National Security

In response to the growing cyber security threats from outside of the United States, the U.S. Government has added an entire new category of sanctioned individuals and organizations to its list of Specially Designated...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

OFAC Announces Settlement with Money Services Business for Violations of Sanctions Programs

On March 23, Department of the Treasury’s OFAC announced a settlement agreement with a large money services business (MSB) for failing to implement an effective compliance program “to identify, interdict, and prevent...more

OFAC Adds 7 Venezuelan Officials to SDN List

On March 8 President Obama signed Executive Order 13692 Executive Order 13692, which initially adds seven former or current Venezuelan government officials to OFAC’s Specially Designated Nationals (SDN) List. Once they have...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

OFAC Announces New Ukraine-Related Designations, Includes Russian National Bank

On March 11, OFAC updated its Specially Designated Nationals (SDNs) list comprising of individuals and entities including a Russian national bank, Russian National Commercial Bank. ...more

White House Issues Executive Order Targeting Venezuela

On March 8, President Obama signed an executive order imposing sanctions on Venezuela in response to the country’s ongoing human rights violations and abuses in anti-governmental protests. Specifically, the Order (i)...more

The Need for Robust OFAC Compliance Programs

People are good at complaining. People often say to themselves, “Things are not going my way,” and they love to feel sorry for themselves. People who are professional victims are toxic....more

Sanctions Enforcement – Facilitation Violations

As sanctions enforcement continues to mature, the permutations of risks become more complex. One area where companies have significant exposure is when they can be accused of “facilitation.” ...more

EU sanctions against Russia: New targets and state of play

On 9 February 2015, the EU Foreign Affairs Council imposed new sanctions - asset freezes and travel bans - against 19 Russian and Ukrainian individuals and 9 entities that have been added to the 'black list' of sanctioned...more

After a busy 2014 for sanctions, what can we expect in 2015?

2014 was a very eventful year for sanctions, with both the European Union (EU) and United States (US) making extensive use of trade sanctions to attain foreign policy goals. Certain sanctions measures against Iran were (and...more

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