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Trump Threatens Sanctions Against The International Criminal Court

The United States has for decades utilized its economic clout to pursue sanctions against rogue governments and regimes, terrorists, narcotics traffickers, and human rights abusers. Now, with roughly half a year left in his...more

The SBA Imposes A $20M Limit On PPP Loans For Corporate Groups

On April 30, 2020, the U.S. Small Business Administration (SBA) issued a sixth interim final rule on the SBA’s Paycheck Protection Program (PPP), one of the relief programs available under the Coronavirus Aid, Relief, and...more

House Passes A $484 Billion Relief Package; Treasury And The SBA Release New Guidelines For PPP Loans

On Thursday, April 23, 2020, the U.S. House of Representatives voted in favor of the $484 billion relief package that passed in the Senate earlier this week. Once signed into law, the legislation will revive the Small...more

Beware Intense Insider Trading Scrutiny In Current Climate

Haima Marlier, David Newman, and Haydn Forrest authored an article for Law360 discussing the increased scrutiny related to insider trading in the time of the coronavirus outbreak, analyzing the investigation into Senator...more

Frequently Asked Questions About The Coronavirus Economic Stabilization Act Of 2020 (CESA)

In response to the COVID-19 public health emergency, which has dramatically affected global commerce, the U.S. healthcare system, and the U.S. economy, on March 27, 2020, the President signed into law the Coronavirus Aid,...more

U.S. Sanctions And Iran’s Coronavirus Challenge

It’s no secret that Iran has been one of the hardest hit countries by COVID-19 (commonly referred to as the “coronavirus”). As in other countries, this outbreak has strained Iran’s healthcare system and has instigated a surge...more

Excusing Performance In The Wake Of Coronavirus (COVID-19)

The cover of this week’s issue of The Economist shows a picture of the globe with a “Closed” sign hanging over it. So what happens when global commerce grinds nearly to a halt, as appears to be happening? And what happens to...more

California Expands Shelter-In-Place Orders Statewide

On Thursday evening, Governor Newsom issued an executive order (the “State Order”) that expanded the shelter-in-place orders already in place in each of the nine San Francisco Bay Area counties broadly directing all...more

OFAC Targets Rosneft Subsidiary . . . In The Venezuela Sanctions Program?

On February 18, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) added Rosneft Trading S.A. (“Rosneft Trading”) and its president to the agency’s List of Specially Designated Nationals and...more

Top 10 Lessons Learned From OFAC’s 2019 Trade-Related Enforcement Actions (OFAC 2019 Year In Review, Part 3)

Over the past few days, we here at MoFo’s National Security Practice Group have outlined the extraordinary pace of activity that the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) maintained in 2019 as...more

Top 10 Lessons Learned From OFAC's 2019 Financial Institution Enforcement Actions (OFAC 2019 Year In Review Part 2)

As we mentioned in the first part of our U.S. Sanctions Year in Review series, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) had an extraordinarily busy year in 2019, and its enforcement activity...more

OFAC 2019 Year In Review (Part 1 of 3)

As we enter 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) may need time to catch its breath after an exceptionally busy year. 2019 showed us that the Trump Administration continues to rely on...more

Coronavirus: Steps Employers Should Be Taking

The World Health Organization (WHO) has now declared the current outbreak of the new coronavirus first identified in Wuhan, Hubei Province, China as a “Public Health Emergency of International Concern.” As more countries...more

DOJ Clarifies Incentives for Voluntary Self-Disclosures of Export Control and Sanctions Violations

On December 13, 2019, the Department of Justice’s National Security Division (“NSD”) announced a revised policy to encourage voluntary self-disclosures (“VSDs”) of criminal violations of export control and sanctions laws. The...more

Congress Pulls the Trigger on Russia’s Nord Stream 2 and TurkStream Pipeline Projects

As it nears the end of the calendar and legislative year, Congress is preparing to take long-awaited action to kill Russia’s Nord Stream 2 and TurkStream natural gas pipeline projects – months before Nord Stream 2’s...more

Congress Adds Potential U.S. Sanctions on Hong Kong to Escalating U.S.-China Tensions (Chinese Edition)

As another sign of the escalating tensions between the United States and China, in addition to the long-running trade war, China this week suspended visits to Hong Kong by the U.S. military and vowed to impose sanctions on a...more

Congress Adds Potential U.S. Sanctions on Hong Kong to Escalating U.S.-China Tensions

As another sign of the escalating tensions between the United States and China, in addition to the long-running trade war, China this week suspended visits to Hong Kong by the U.S. military and vowed to impose sanctions on a...more

Trump Reverses Course on Turkey

On October 23, 2019, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced it was removing three Turkish government ministers and two Turkish government ministries from its list of Specially Designated...more

Trump on Turkey: Sanctions on a NATO Ally Today, With Escalation or Removal Possible Tomorrow

On October 14, President Trump issued an Executive order (“E.O.”) imposing sanctions on Turkey in response to Turkey’s military offensive in northern Syria. New E.O. 13894 authorizes the U.S. Departments of State and the...more

Terrorism Sanctions Go Secondary

As part of the 18th anniversary of the September 11 attacks earlier this month, the Trump Administration effectively declared the old adage that “one person’s terrorist is another person’s freedom fighter” does not apply with...more

Back to the Future: Helms-Burton Versus the Blocking Statutes. Who Will Prevail?

Nearly a quarter century after its passage, the Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996 – commonly known as Helms-Burton, after its sponsors – was expected to revive a significant number of old disputes...more

Not Quite Cuba (Yet): OFAC Blocks The Venezuelan Government’s Property

Hot on the heels of the “Saturday Surprise,” the Trump Administration initiated “Monday Madness” earlier this week when the President issued new Executive Order (E.O.) 13884 blocking any property and interests in property of...more

TGIF? No, CBW: U.S. Government Imposes Narrow Financing Restrictions and Other Sanctions on Russia

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has a well-earned reputation in the sanctions bar for ruining weekends. The agency responsible for implementing and enforcing U.S. economic sanctions has...more

OFAC’s Framework for Sanctions Compliance and its Impact on Recent Enforcement Cases

On May 2, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published its first-ever Framework for OFAC Compliance Commitments (“Framework”), detailing the essential components of a sanctions...more

For Russia, Sanctions Are Coming

Back in February, we told you about the Defending American Security from Kremlin Aggression Act, or “DASKA,” a bipartisan effort to impose new sanctions on Russia. Interest in action against the Kremlin has only increased...more

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