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OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

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

U.S. Appeals Court limits OFAC’s sanctions authority in cryptocurrency mixer case

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

U.S. Treasury announces new sanctions targeting Russian banks, warns foreign financial institutions from using Russian alternative...

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

Significant new measures against Russia issued by US Departments of Treasury, State, and Commerce

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

OFAC issues interim final rule amending blocked property and other reporting requirements

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

U.S., EU, and UK expand sanctions to mark the second anniversary of Russia’s war in Ukraine

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

Significant new U.S., UK and EU measures mark anniversary of Russia’s invasion of Ukraine

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

OFAC Authorizes Transactions in Listed Sectors in Connection with Non-Regime Held Areas of Syria

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

Treasury Department issues inter-agency business advisory on Burma

On January 26, 2022, the U.S. Department of the Treasury issued an advisory for businesses and individuals doing business in Burma. Specifically, the business advisory cautions business and individuals to be aware of exposure...more

Biden Administration sanctions target Russian technology and defense sectors and Russian sovereign debt

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

U.S. imposes new sanctions and export controls on Burma

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

U.S. Imposes Sanctions on Turkish Presidency of Defense Industries

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

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