On 20 June 2019 the Department of Treasury's Office of Foreign Assets Control (OFAC) issued a final interim rule (effective on 21 June 2019) amending its reporting, procedures, and penalties regulations, 31 Code of Federal...more
7/26/2019
/ Confidential Information ,
Disclosure Requirements ,
Economic Sanctions ,
Factoring Transactions ,
FOIA ,
Food Marketing Institute v Argus Leader Media ,
Interim Rule ,
License Applications ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Regulatory Oversight ,
Regulatory Requirements ,
Reporting Requirements
On 2 May 2019, the U.S. Treasury's Office of Foreign Assets Control ("OFAC"), the agency responsible for enforcing economic sanctions, published "A Framework for OFAC Compliance Commitments" (the "Framework") which outlines...more
7/3/2019
/ Cooperative Compliance Regime ,
Economic Sanctions ,
Failure to Comply ,
Foreign Policy ,
Foreign Relations ,
Framework Agreement ,
Fund Managers ,
Internal Controls ,
Investment Funds ,
Investment Management ,
Office of Foreign Assets Control (OFAC) ,
Private Equity ,
Risk Assessment ,
Sanction Violations
On 4 June 2019 the Trump administration implemented certain regulatory changes first announced on 17 April 2019 by National Security Advisor Ambassador John Bolton in a foreign policy address regarding the Trump...more
On 2 May 2019 the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued "A Framework for OFAC Compliance Commitments" (the framework), which outlines five components OFAC considers to be essential...more
OFAC has announced a Finding of Violation –and not a penalty–against State Street Bank and Trust Co. (SSBT) for processing 45 pension payments totaling under $12,000 on behalf of a pension plan participant who was a US...more
On 19 December 2018, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) submitted a notification to Congress that it plans to terminate sanctions on three major companies originally designated for...more
The past two weeks have entailed a flurry of sanctions developments related to Russia, including the issuance of a new executive order, and the designation of a number of entities by the U.S. Department of the Treasury's...more
The United States has begun re-imposing nuclear-related sanctions with respect to Iran in connection with the expiration of the 90-day wind-down period announced alongside the United States' 8 May 2018 withdrawal from the...more
8/13/2018
/ Economic Sanctions ,
Energy Sector ,
Financial Institutions ,
Foreign Investment ,
Foreign Policy ,
Foreign Relations ,
Insurance Industry ,
Iran ,
Iran Sanctions ,
ITSR ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Shipping
In furtherance of President Trump’s 8 May 2018 announcement that the United States would withdraw from the Iran nuclear deal—the Joint Comprehensive Plan of Action (JCPOA)—on 27 June 2018, the U.S. Department of Treasury’s...more
Declaring that it is “defective at its core,” on 8 May 2018, President Trump announced that the United States would withdraw from the Iran nuclear deal and begin re-imposing sanctions that were lifted pursuant to U.S....more
Today, the Trump Administration designated multiple Russian targets, including several wealthy individuals and their companies, as Specially Designated Nationals (SDNs). These designations of major companies represent the...more
On Monday, 29 January, the U.S. Treasury Department submitted an unclassified report to Congress concerning significant senior political figures and oligarchs in the Russian Federation and Russian parastatal entities.
...more
On December 20, 2017, President Trump issued Executive Order 13818 implementing the Global Magnitsky Act, and the Office of Foreign Assets Control (OFAC) issued the first designations responsive to this statute.
...more
On 9 November 2017, the Trump Administration implemented new regulations to support its change to U.S. policy on Cuba. The U.S. Government has created a new Cuba Restricted List administered by the State Department. Through...more
Yesterday, on October 12, 2017, the U.S. permanently revoked most sanctions against Sudan. This lifting represents the completion of a process that began in January 2017, and was extended in July 2017. ...more
10/13/2017
/ Agricultural Sector ,
Banking Sector ,
Charitable Organizations ,
Commerce Control List ,
Economic Sanctions ,
Export Controls ,
Medical Devices ,
Office of Foreign Assets Control (OFAC) ,
Pharmaceutical Industry ,
SDN List ,
State Sponsors of Terrorism ,
Sudan ,
Universities
Effective August 25, 2017, President Trump issued a new Executive Order, (the Order), which targets the Government of Venezuela’s (GOV) and Petroleos de Venezuela, S.A.’s (PdVSA) ability to access capital from the United...more
One day after the Venezuelan government held elections for a Constituent Assembly that the United States has asserted is aimed at rewriting the national constitution, the Department of the Treasury’s Office of Foreign Assets...more
Ahead of a Constituent Assembly that could re-write the Venezuelan Constitution and dissolve state institutions, the U.S. Treasury Department’s Office of Foreign Assets Control has designated 13 current and former Venezuelan...more
On Friday, 16 June 2017, President Trump made his first major foray into U.S. - Cuban relations since assuming office. While it was a radical departure in tone from his predecessor, the changes he announced appear to leave...more
On Friday, February 3, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced it was designating 25 entities and individuals as Specially Designated Nationals (SDNs) for their involvement in...more
2/14/2017
/ Foreign Policy ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
National Security ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Procurement Guidelines ,
SDN List ,
Terrorist Threats ,
Trump Administration ,
U.S. Treasury ,
WMD
On December 23, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a number of changes to the Iranian Transactions and Sanctions Regulations (“ITSR,” 31 C.F.R. Part 560) that expanded the...more
1/20/2017
/ Agricultural Sector ,
Commodities ,
Export Controls ,
Exports ,
General Licenses ,
Healthcare ,
Imports ,
Iran ,
Iran Sanctions ,
Manufacturers ,
Medical Devices ,
Obama Administration ,
Office of Foreign Assets Control (OFAC) ,
Pharmaceutical Industry ,
Software