The US Office of Foreign Assets Control (OFAC) issued Syria General License 24 (GL 24) authorizing certain transactions with the new Syrian government and easing some transactions related to energy and personal remittances....more
Marking what appears to be a reversal of previous policy, the Office of Foreign Assets Control (OFAC) determined that US persons can, subject to certain limitations, include sanctioned persons as speakers at overseas...more
In a ruling eagerly awaited by the cryptocurrency industry, the US Court of Appeals for the Fifth Circuit held that immutable smart contracts on the Tornado Cash crypto-transaction software protocol are not “property” subject...more
The US Office of Foreign Assets Control recently amended its insurance-related FAQ and issued two new FAQs. This focus on insurance-related guidance comes at the same time as an enforcement action targeting an insurer that...more
OFAC’s new FAQ 1097, issued October 10, warns US investors of the need to block securities held at Russia’s National Settlement Depository (NSD), even if the securities or the issuer is not sanctioned. Even if the security is...more
The US Office of Foreign Assets Control first issued the Syrian Sanctions on April 5, 2005, implementing Executive Order 13338, “Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria.” On...more
The Biden administration suspended certain sanctions on the Government of Venezuela, including some impacting Petróleos de Venezuela S.A. (PdVSA), on October 18, 2023. This significant, albeit currently temporary, change in...more
The US Department of the Treasury’s Office of Foreign Assets Control issued a Determination on December 5 implementing a $60 “price cap” on Russian crude oil, pursuant to which US persons are authorized to provide otherwise...more
Based on the evolving military operations of the Russian Federation in Ukraine, the United States has imposed additional sanctions on the Russian Federation, Russian leadership, and various financial institutions and...more
In response to the Russian Federation’s recognition of certain regions of Ukraine as independent states which followed an expansion of nearly 200,000 troops on the Ukrainian border, US President Joseph Biden authorized the...more