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OFAC Year-in-Review 2021 Part II – Lessons Learned from OFAC’s 2021 Enforcement Actions

Back in July, we took a look at the enforcement actions for the first half of 2021 issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Today’s post – the second half of our OFAC 2021 Year...more

OFAC Year in Review 2021 – Part 1

2021 was a year of transition in the United States and for the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s year, while busy, was far different from 2020, as the Biden Administration’s...more

OFAC 2020 Year In Review

In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more

OFAC Issues Advisory Highlighting Art Trade No “Goghs”

On October 30, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published an advisory highlighting potential sanctions risks arising from dealings in “high-value artwork” (with “particular...more

Hong Kong In The Crosshairs: Secretary Of State Submits Hong Kong Autonomy Act Report To Congress, Paving Path For Secondary...

On Wednesday, October 14, 2020, the U.S. Department of State (“State”) submitted a report to the U.S. Congress, as required under section 5(a) of the Hong Kong Autonomy Act (“HKAA”), identifying foreign persons materially...more

U.S. “Maximum Pressure” Campaign Expands Isolation Of Iran’s Financial Sector

On Thursday, October 8, 2020, U.S. Secretary of the Treasury Steven Mnuchin identified the Iranian financial sector as subject to the sectoral sanctions of Executive Order (“E.O.”) 13902, escalating the formidable Trump...more

Sanctions Spree: New Round Of Sanctions Against China And Russia

Amid the COVID-19 pandemic and Black Lives Matter demonstrations, the U.S. Congress has stepped up its election year efforts by threatening heightened sanctions on China and Russia. The latest such bill, the Hong Kong...more

OFAC Issues New FAQs Clarifying Iran Secondary Sanctions

On June 5, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued four new frequently asked questions (“FAQs”) that define key terms used in secondary sanctions added to the Iran sanctions...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

Navigating Iran Sanctions after JCPOA’s Implementation Day

The announcement by the International Atomic Energy Agency on January 16, 2016, that the Government of Iran has satisfied its commitments under the Joint Comprehensive Plan of Action (“JCPOA”), has triggered “Implementation...more

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