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Terrorism Designations Primer: Process, Authorities, and Recourse

Since the mid-1990s, the Executive Branch has sought to target foreign terrorist organizations, and those individuals and organizations supporting them, in order to degrade their funding and support. Organizations and...more

U.S. Sanctions Enforcement: 2024 Lessons Learned and 2025 Expectations

As the third month of the second Trump administration comes to a close, the lack of any public enforcement action by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctions watchers...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

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

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

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

The United States Imposes Additional Secondary Sanctions on Iran as Geopolitical Tensions Flare

With tensions rising in the Persian Gulf, and Iran on the brink of pulling out of portions of the Iran nuclear deal, President Trump issued new Executive Order 13871 last Wednesday, May 8, 2019, imposing sanctions on Iran’s...more

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