General License 25 effectively suspends OFAC sanctions targeting Syria. Stringent US export control restrictions on exports and reexports to Syria remain....more
5/28/2025
/ Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Syria ,
Trump Administration ,
U.S. Treasury ,
UK
The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....more
2/25/2025
/ Anti-Money Laundering ,
Cartels ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Priorities ,
Executive Orders ,
Financial Institutions ,
Foreign Entities ,
Foreign Financial Institutions (FFI) ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Significant Transnational Criminal Organization ,
Terrorist Organizations ,
U.S. Treasury
The court ruled OFAC overstepped its authority in sanctioning Tornado Cash, holding that its smart contracts are not “property” under the governing statutes....more
Companies that promptly self-disclose and remediate potential violations of administrative or criminal law may significantly mitigate liability.
On July 26, 2023, the US Departments of Justice (DOJ), Commerce, and the...more
8/3/2023
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Authority ,
Export Controls ,
Exports ,
Joint Policy Statements ,
Joint Statements ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Self-Reporting
New measures expand existing sanctions and export controls, including by restricting medical item exports and targeting Russia’s architecture and engineering sectors.
This Client Alert is published in the context of...more
New announcements and rules expand the scope of existing sanctions and export controls on Russia.
This Client Alert is published in the context of ongoing developments and should be read in conjunction with the Latham’s...more
3/16/2023
/ Biden Administration ,
Blocked Person ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Embargo ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Infrastructure ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Pipelines ,
Russia ,
SDN List ,
Ukraine
The price cap operates as an exemption to the ban on transportation of Russian seaborne crude oil to other countries.
This Client Alert is published in the context of ongoing developments and should be read in conjunction...more
12/12/2022
/ Crude Oil ,
Economic Sanctions ,
EU ,
G7 ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia ,
Safe Harbors ,
UK ,
Ukraine
The US Treasury opens a Pandora’s box of legal issues as it targets a decentralized finance protocol used for both licit and illicit means.
On August 8, 2022, the US Department of the Treasury’s Office of Foreign Assets...more
8/12/2022
/ Blockchain ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Economic Sanctions ,
Ethereum ,
Foreign Policy ,
Money Laundering ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
SDN List ,
U.S. Treasury
The measures prohibit gold imports and add new SDN, Entity List, and asset freeze designations.
This Client Alert is published in the context of ongoing developments and should be read in conjunction with the Latham &...more
7/5/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Biden Administration ,
Economic Sanctions ,
Export Controls ,
General Licenses ,
Japan ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
UK ,
Ukraine
OFAC has also extended certain general licenses, while BIS has continued to restrict exports to Russia.
This Client Alert is published in the context of ongoing developments and should be read in conjunction with the...more
New rules and announcements expand existing sanctions and export controls relating to Russia.
This Client Alert is published in the context of ongoing developments and should be read in conjunction with the Latham &...more
5/16/2022
/ Biden Administration ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
UK ,
Ukraine
The DOJ’s National Cryptocurrency Enforcement Team and Treasury’s OFAC are setting their sights on cryptocurrency use in cybercrimes.
The US Department of Justice (DOJ) is sharpening its focus on combatting...more
10/29/2021
/ Blockchain ,
Compliance ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Enforcement Authority ,
Financial Crimes ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
SDN List ,
U.S. Treasury ,
Virtual Currency
New restrictions prohibit dealings between US persons and the Government of Venezuela.
On August 5, 2019, President Trump issued Executive Order (E.O.) 13884, entitled “Blocking the Property of the Government of...more
OFAC outlines baseline considerations for evaluating a risk-based sanctions compliance program.
On May 2, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance...more
5/9/2019
/ Audits ,
Black & Decker ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Corporate Management ,
Economic Sanctions ,
Enforcement Actions ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Training
OFAC adds PdVSA to its sanctions list and simultaneously issues general licenses temporarily allowing certain transactions and activities involving PdVSA.
On January 28, the US Treasury Department’s Office of Foreign...more
OFAC added several parties to the SDN List and simultaneously issued a General License, authorizing certain wind-down activities until January 8, 2020.
Today, the Treasury Department’s Office of Foreign Assets Control...more
Withdrawal from the Iran nuclear agreement triggers full implementation of US sanctions, including threat of “secondary” sanctions on non-US persons dealing with Iran.
As reported in the Latham Client Alert dated May 10,...more
11/6/2018
/ Economic Sanctions ,
EU ,
Financial Institutions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trump Administration
In light of the EU’s recent amendments to its long-standing blocking measure, EU operators will need to weigh the consequences of failing to comply with their contradicting obligations under US and EU law.
How has the EU...more
Withdrawal from the JCPOA will lead to re-imposition of several categories of US sanctions.
On May 8, 2018, President Trump announced that the United States will withdraw from the Joint Comprehensive Plan of Action...more
The new designations of Russian individuals and entities broadly expand the scope and impact of sanctions.
Background -
On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (OFAC) added more...more
4/13/2018
/ Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
U.S. Treasury ,
Ukraine
The new designations of Russian individuals and entities broadly expand the scope and impact of sanctions.
Background -
On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (OFAC) added more...more
4/10/2018
/ Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Government Officials ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Trump Administration ,
U.S. Treasury
Treasury Department Report identifies 114 senior political figures and 96 oligarchs, and confirms that the Report is not a sanctions list -
On January 29, 2018, the Treasury Department submitted a report to the US Congress...more
Treasury Department Report identifies 114 senior political figures and 96 oligarchs, and confirms that the Report is not a sanctions list -
On January 29, 2018, the Treasury Department submitted a report to the US...more
Venezuela’s initiative is unlikely to set the stage for a restructuring of international obligations in the face of US sanctions.
Key Points:
- US sanctions will prohibit US persons from engaging in a restructuring of...more
President Trump signs the “Countering America’s Adversaries Through Sanctions Act,” which — among other measures — requires Congressional review to ease Russia-related sanctions.
On Wednesday, August 2, 2017, President...more
9/16/2017
/ Asset Freeze ,
Congressional Authority ,
Cybersecurity ,
Economic Sanctions ,
Foreign Relations ,
Human Rights ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
SDN List ,
Secondary Sanctions ,
Terrorism Funding ,
Trump Administration