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Sudan Update: OFAC Issues Guidance Clarifying Status of U.S. Sanctions and Export Controls

On August 11, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new guidance document, the Sudan Program and Darfur Sanctions Guidance (“Sudan Guidance”), which clarifies the current...more

OFAC Issues Sanctions Against Additional Rosneft Subsidiary and Amends Venezuelan General Licenses

On March 12, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued sanctions against a second affiliate of PJSC Rosneft Oil Company (“Rosneft”) related to its activities with Venezuela. OFAC...more

U.S. Expands Secondary Sanctions to Iran’s Industrial Sectors

On January 10, 2020, the United States imposed additional sanctions on Iran in the wake of recent tensions between the countries and the continuing broader ‘maximum pressure’ campaign on Iran. ...more

District Court Overturns OFAC Fine Against Exxon

On December 31, 2019, the U.S. District Court for the Northern District of Texas overturned a $2 million fine imposed by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) against ExxonMobil Corp., and...more

Cuba Travel Update: U.S. Regulators Amend Key Rules

On June 5, 2019, the Department of Commerce Bureau of Industry and Security (BIS) amended an important license exception which generally permitted the temporary sojourn of civil aircraft and vessels to Cuba.  ...more

OFAC Announces Sanctions Against Saudi Arabian Government Officials Pursuant to Global Magnitsky Act

On November 15, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 17 officials of the Government of Saudi Arabia for their purported role in the killing of journalist Jamal...more

Reinstatement of Iran Sanctions

On November 5, 2018, OFAC announced a large number of Iran-related sanctions designations and issued guidance on the end of the 180-day wind down period. ...more

Completing “Snap-Back”

On November 2, 2018, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a final rule effective Monday, November 5, 2018 that amends the Iranian Transactions and Sanctions Regulations and reinstates...more

U.S. Formalizes Snap-Back of Sanctions with New Executive Order

On August 6, 2018, the Treasury Department’s Office of Foreign Assets Control (OFAC) released a new Executive Order to implement the previously announced re-imposition of U.S. sanctions for Iran. ...more

Treasury Department Designates Russian Oligarchs, Officials, and Entities

The Treasury Department has placed several prominent Russian individuals and companies on the Specially Designated Nationals and Blocked Persons lists (“SDN list”). Several of these parties are Russian billionaires previously...more

U.S. Targets Human Rights Abusers and Corrupt Actors Worldwide – Key Takeaways from the Potent New Sanctions

On December 20, 2017, President Trump issued Executive Order 13818 (the “E.O.”) implementing provisions of the Global Magnitsky Human Rights Accountability Act (“Global Magnitsky Act”) (enacted into law in December 2016),...more

Evolving U.S. and UN Sanctions Against North Korea

Following President Trump’s trip to Asia, sanctions policies for North Korea continue to evolve. The U.S. government has strengthened sanctions through legislation and Presidential Executive Orders. Further, it is enforcing...more

U.S. Government Agencies Publish Changes to Cuba Sanctions Program Pursuant to President Trump’s Policy Announcement

On November 8, 2017, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) and the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced amendments to the Cuban Assets Control Regulations...more

Russia Sanctions under CAATSA – U.S. Updates Rules and Provides Guidance on Enforcement

This week, the U.S. government took several steps to implement sections of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA), with implications for Russia-related sanctions and their enforcement. On...more

A UK Version of OFAC?

The Office of Financial Sanctions Implementation ramps up enforcement activities in London - A new UK sanctions enforcement body with added civil enforcement tools is ramping up activities. ...more

Another Market Opens: U.S. Revokes Sudanese Sanctions Program Though Important Limitations Remain in Place

Effective October 12, 2017, the Sudanese Sanctions Regulations (SSR) have been revoked in recognition of the Government of Sudan’s (GOS) sustained positive actions in stopping conflict and improving humanitarian access in...more

OFAC Updates FAQs on the Cuba Sanctions Program

On June 16, 2017, President Trump issued a National Security Presidential Memorandum on Strengthening the Policy of the United States Toward Cuba, which began the process to alter some aspects of U.S. policy toward Cuba. On...more

President Trump Announces Policy Changes Towards Cuba

On June 16, 2017, President Trump issued a National Security Presidential Memorandum on Strengthening the Policy of the United States Toward Cuba, which begins a process to alter some aspects of U.S. policy towards Cuba, but...more

General License for Commercial Authorizations from Sanctioned Russian Security Agency

OFAC has issued a new General License to address problems raised by the sanctioning of the Federal Security Services (FSB). This adjustment serves to authorize permits by the FSB needed for certain commercial transactions...more

New General License Authorizes Transactions with Sudan

Effective January 17, 2017, a new general license authorizes a broad range of activities previously prohibited under the Sudanese Sanctions Regulations (SSR), including most transactions with individuals and entities in Sudan...more

New OFAC Guidance Offers Clarity on Operations Involving Iran

On December 15, 2016, the Office of Foreign Assets Control (OFAC) provided updated guidance on what companies can expect in the event of the “snapback” of sanctions under the Joint Comprehensive Plan of Action (JCPOA). ...more

On the Eve of a New Administration, Sanctions on North Korea Tighten

On November 30, 2016, the United Nations Security Council (UNSC) passed a unanimous resolution strengthening sanctions against North Korea. The Resolution comes in response to the conduct of the latest round of nuclear tests...more

U.S. Government Continues to Create New Opportunities for Trade with Cuba

Both the U.S. Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) have announced new amendments to the Cuban Assets Control Regulations (CACR) and Export...more

OFAC Provides Helpful New Guidance for Cuba

The Office of Foreign Assets Control (OFAC) updated its FAQs for Cuba on April 21, 2016 with substantive guidance that addresses U-turn transactions, export policy, insurance, educational and humanitarian activities and...more

Additional Steps to Ease U.S. Sanctions and Export Controls for Cuba prior to Obama Visit

In advance of President Obama’s highly publicized trip to Cuba, the Administration took additional steps to ease restrictions on trade and travel with Cuba. These changes to the Cuban Assets Control Regulations (CACR) and...more

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