The U.S. Department of State has formally republished the Cuba Restricted List, restoring prohibitions on direct financial transactions with numerous Cuban military, intelligence, and security-linked entities. This move...more
The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more
New U.S. and UK sanctions target Russia’s energy sector and supporting infrastructure. On January 10, 2025, the United States and the United Kingdom imposed additional sanctions against Russia, with a focus on its energy...more
The Fifth Circuit held that Tornado Cash, open-source computer code known as an immutable “smart contract”, is not “property” and thus cannot be subject to blocking sanctions pursuant to IEEPA and EO 13694....more
The U.S. Department of the Treasury’s Office of Foreign Assets Control has designated dozens of Russian banks including Gazprombank and issued an alert warning foreign financial institutions of the risk of U.S. sanction for...more
On October 30, 2024, the US government imposed additional trade controls to target procurement networks supporting Russia’s military and defense-industrial system. These additional trade controls include sanctioning 400...more
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has issued guidance on best practices for submitting information and documents in response to OFAC administrative subpoenas, requests for...more
On 12 June 2024, the US Departments of Treasury, State, and Commerce imposed new restrictions targeting Russia, including: (i) restricting the provision of certain information technology and software services to Russia...more
The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an interim final rule set to take effect August 8, 2024, which amends the Reporting, Procedures, and Penalties Regulations (the “Regulations”)...more
Following the death of political activist Aleksey Navalny and to mark the second anniversary of Russia’s invasion of Ukraine, the United States, EU and UK adopted a series of amendments to their respective economic sanctions...more
On December 22, 2023, President Biden issued a new Russia-related Executive Order (“EO”) targeting foreign financial institutions (“FFIs”) that support Russia’s military-industrial base. The new EO allows the U.S. government...more
On 24 February 2023, the U.S. intensified its sanctions on Russia and released new trade control measures targeting key sectors, evasion efforts, and military supplies. Taken together, the additional sanctions, export...more
The Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) No. 22 on May 12, 2022, authorizing transactions that are ordinarily incident and necessary to activities that occur in specified, non-regime held...more
On February 24, 2022, the US Government imposed severe economic sanctions and export controls on Russia. The restrictions consist of two parts: 1) significant financial sanctions on a range of Russian financial institutions...more
On 15 April 2021, the U.S. Government announced a number of new sanctions measures against Russia, targeting a variety of “harmful foreign activities” contrary to U.S. foreign policy. ...more
4/21/2021
/ Biden Administration ,
Crimea ,
Critical Infrastructure Sectors ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts
On 11 February 2021, President Biden issued Executive Order 14014 "Blocking Property with Respect to Burma" (EO), which authorizes the imposition of sanctions on specific persons or entities in Burma, including Burmese...more
2/23/2021
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Foreign Policy ,
Insurrection ,
Myanmar ,
Office of Foreign Assets Control (OFAC) ,
SDN List
The State Department announced the imposition of sanctions on the Republic of Turkey’s Presidency of Defense Industries (“SSB”), and four related Turkish individuals under the Countering America’s Adversaries Through...more
The Trump Administration announced a more restrictive policy towards Cuba in a presidential memo issued in June 2017. Since then, the Administration has implemented initiatives that have narrowed or revoked authorized trading...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