On June 24, 2024, the Commerce Department published a Final Determination under its Information and Communications Technology and Services (ICTS) authorities. The determination prohibits the Russian-controlled cybersecurity...more
7/16/2024
/ CFIUS ,
Corporate Counsel ,
Covered Transactions ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Executive Orders ,
FCC ,
Foreign Adversaries ,
Information and Communication Technology (ICT) ,
Information Systems Security Program (ISSP) ,
National Security ,
Risk Assessment ,
Russia ,
Software ,
U.S. Commerce Department
On June 12, 2024, the United States took several hard-hitting sanctions- and export control-related actions intended to intensify pressure on the Russian government and hamper Russia’s ability to continue to support its war...more
6/19/2024
/ Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Financial Institutions (FFI) ,
General Licenses ,
Information Technology ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Secondary Sanctions ,
Software ,
Supply Chain ,
U.S. Commerce Department
On March 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its first enforcement case of the year and its first ever involving dealings with a Russian designated for sanctions...more
3/25/2024
/ Corporate Counsel ,
Cuban Assets Control Regulations (CACR) ,
Due Diligence ,
Economic Sanctions ,
Enforcement ,
Executive Orders ,
Export Controls ,
Foreign Narcotics Kingpin Sanctions Regulations (FNKSR) ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Russia ,
Securities Transactions ,
U.S. Treasury
Today’s alert—the second in our Sanctions 2023 Year in Review Series—provides an overview of U.S. sanctions enforcement in 2023, including the key lessons learned from the public enforcement actions issued by the U.S....more
3/5/2024
/ Bureau of Industry and Security (BIS) ,
CFTC ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Economic Sanctions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
SDN List ,
Technology ,
Ukraine ,
Virtual Currency ,
Whistleblowers
2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more
3/4/2024
/ China ,
Corporate Counsel ,
Critical Infrastructure Sectors ,
Cybersecurity ,
Decentralized Finance (DeFi) ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
Hamas ,
Human Rights ,
National Security ,
NDAA ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Terrorist Acts ,
U.S. Treasury ,
Ukraine ,
US State Departments ,
Venezuela ,
Virtual Currency
After two years of aggressive sanctions against Russia for its ongoing war in Ukraine, the United States has broadly expanded those sanctions to threaten foreign financial institutions (FFIs) that support Russia’s...more
Today’s alert—the third and final installment in our Sanctions 2022 Year in Review series—provides an overview of U.S. sanctions enforcement in 2022, including the key lessons learned from the enforcement actions issued by...more
As Russia’s war in Ukraine passes the one-year mark, and the battles on the ground move forward with escalating levels of ferocity, governments around the world continue to coordinate and respond with increasingly severe...more
3/3/2023
/ Asset Freeze ,
Bureau of Industry and Security (BIS) ,
Central Bank of Russia ,
Economic Sanctions ,
EU ,
Export Controls ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
UK ,
Ukraine
2022 was an unprecedented year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). While the sweeping new U.S. sanctions imposed against Russia and Belarus in unparalleled...more
3/2/2023
/ Burma ,
China ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
Human Rights ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
UN Security Council ,
United Nations ,
Venezuela ,
Virtual Currency
When Russia invaded Ukraine earlier this year, the international outcry was immediate. Governments around the world took steps to isolate Russia economically and diplomatically. In the United States, most of the attention has...more
After months of negotiations, Congress revealed the compromise version of the National Defense Authorization Act for Fiscal Year 2023 (NDAA) on December 6, 2022. The bill, viewed as a “must-pass” piece of legislation because...more
12/15/2022
/ Burma ,
China ,
Department of Defense (DOD) ,
Drug Trafficking ,
Economic Sanctions ,
Export Controls ,
Financial Institutions ,
Foreign Investment ,
Human Rights ,
Iran ,
NDAA ,
Popular ,
Russia ,
Semiconductors ,
Supply Chain
As Russia’s war in Ukraine stretches into its tenth month, governments around the world continue to coordinate and respond with increasingly severe sanctions and export controls....more
12/7/2022
/ Crude Oil ,
Economic Sanctions ,
EU ,
Export Controls ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Reporting Requirements ,
Russia ,
UK ,
Ukraine
Revised draft legislation circulated June 13th is the most recent salvo in a long-running effort that is increasingly likely to create an unprecedented outbound investment review mechanism in the United States. ...more
6/17/2022
/ CFIUS ,
China ,
Critical Infrastructure Sectors ,
Department of Agriculture ,
Department of Health and Human Services (HHS) ,
Department of Homeland Security (DHS) ,
Foreign Entities ,
Foreign Investment ,
National Security ,
Russia ,
Trade Representatives ,
Written Notice
As Russia’s bloody invasion of Ukraine nears the end of its second month, with regular reports of human rights violations, possible chemical weapons attacks, and head of state musings regarding whether this campaign amounts...more
4/18/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Markets ,
Foreign Relations ,
Japan ,
Most-Favored Nations ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Trade Relations ,
UK ,
Ukraine
As Russia’s brutal invasion of Ukraine stretches on into its second month, the United States, European Union, United Kingdom, and other global allies have continued to pour additional funding and arms into Ukraine while...more
3/23/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Funding ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SWIFT ,
UK ,
Ukraine ,
US Department of State
On March 2, 2022, the U.S. Department of Justice announced the launch of Task Force KleptoCapture, an interagency law enforcement task force dedicated to enforcing the unprecedented sanctions, export, and other measures taken...more
After less than a week of a full-scale war between Russia and Ukraine, the post-Cold War global architecture appears irrevocably shattered, as Western nations line up to offer support and military and economic aid to Ukraine...more
3/1/2022
/ Airspace ,
Asset Freeze ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
G7 ,
Popular ,
Russia ,
SWIFT ,
UK ,
Ukraine ,
United States
2021 was a year of transition in the United States and for the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s year, while busy, was far different from 2020, as the Biden Administration’s...more
2/8/2022
/ Biden Administration ,
Burma ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Forced Labor ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Iran ,
NDAA ,
NGOs ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
U.S. Treasury
In response to Russia’s increasingly aggressive troop build-up on the Ukrainian border and the lack of progress of negotiations between Russia and the United States, Democrats and Republicans in Congress appear united in...more
As we approach year’s end, and the pace of legislative activity ramps up, it remains critical to keep a close eye on the sanctions-related bills currently making their way, at varying speeds, through the U.S. legislative...more
11/9/2021
/ China ,
Corruption ,
Forced Labor ,
Foreign Policy ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
U.S. Treasury
In the latest turn of events in the seemingly never-ending political saga of the Nord Stream 2 pipeline, the U.S. House of Representatives (the “House”), via an amendment to the 2022 National Defense Authorization Act...more
10/7/2021
/ CAATSA ,
Foreign Entities ,
Germany ,
Joe Biden ,
National Interest Waiver ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
Sanctions ,
Trump Administration ,
US State Departments
The legal and political skirmishing continued on both sides of the Atlantic in recent weeks over Nord Stream 2, the nearly finished Russian natural gas pipeline that continues to serve as a flash point within Europe and...more
On April 15, 2021, following discussions just days earlier of a potential summit between President Biden and Russian President Putin and as Russian troops amassed along the Ukrainian border, the Biden Administration issued...more
4/20/2021
/ Biden Administration ,
Blocked Person ,
CBW Act ,
Cybersecurity ,
Defense Sector ,
Espionage ,
Executive Orders ,
Export Controls ,
Foreign Interference in US Elections ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts ,
Technology Sector ,
Ukraine ,
Vladimir Putin
In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more
2/16/2021
/ China ,
Corporate Counsel ,
Cuban Assets Control Regulations (CACR) ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Financial Institutions (FFI) ,
Iran Sanctions ,
Maritime Transport ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Pentagon ,
Pipelines ,
Popular ,
Ransomware ,
Russia ,
SDN List ,
Trump Administration