On September 5, 2024, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) released General License (“GL”) 108 (“Authorizing Limited Safety and Environmental Transactions Involving Certain Blocked...more
On August 27, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced amendments to two key FAQs (FAQs 736 and 757) concerning the Cuban Assets Control Regulations (“CACR”). These FAQs...more
In a recent enforcement action, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a civil penalty on a U.S. company for violations of the antiboycott provisions under Part 760 of the Export...more
On April 24, 2024, President Biden signed into law the "Making Emergency Supplemental Appropriations for the Fiscal Year Ending September 30, 2024, and for Other Purposes" Act. This law mandates that the United States...more
On August 23, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 103 ("Authorizing Transactions Related to Imports of Certain Diamond Jewelry Prohibited by...more
On June 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) intended to strengthen and modernize U.S. financial institutions’...more
On August 23, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) announced a series of new measures to further restrict the supply of U.S.-origin and "U.S.-branded" items to Russia and Belarus...more
The U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) on (i) July 10, 2024, extended General License (“GL”) 13J (“Authorizing Certain Administrative Transactions Prohibited by Directive 4 under...more
On July 23, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) issued a new reporting requirement following the enactment of the Rebuilding Economic Prosperity and Opportunity for Ukrainians...more
An August 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) further delayed to November 12, 2024, U.S. persons’ rights as bondholders of Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5%...more
On August 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a series of new initiatives to assist the public to better understand sanctions and the role of the private sector...more
On July 1, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released an updated version of Don’t Let This Happen To You!, which contains summaries of actual investigations of Export Control and...more
OFAC Licensing Portal and Hotline Updates -
On July 18, 2024, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) provided information regarding updates to its Licensing Portal. The updates are...more
The Venezuela Sanctions Regulations, 31 CFR Part 591 (“VSR”), which was enacted pursuant to Executive Order (“EO”) 13850 of November 1, 2018 (“Blocking Property of Additional Persons Contributing to the Situation in...more
On August 2, 2024, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License ("GL") 99A, which authorizes through October 12, 2024, the wind-down of transactions...more
Effective as of June 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced several additional export control restrictions and related actions against Russia and Belarus to further...more
On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new Determination Pursuant to Section 1 (a)(ii) of Executive Order 14071 (the “Determination”) that prohibits U.S....more
On April 24, 2024, President Biden signed into law H.R. 815 (Pub. L. 118-50), “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes” (the “Act”), which includes...more
On June 5th, 2024, the United States Court of Appeals for the Fifth Circuit (the “Court”) vacated the U.S. Securities and Exchange Commission’s (“SEC’s”) private fund advisers rules (the "Rules"), which would have imposed...more
On May 17, 2024, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a Final Rule revising the Section 232 tariff exclusion process for imported steel and aluminum products. Effective July 1,...more
On March 7, 2024, at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa O. Monaco unveiled the Department of Justice's (“DOJ”) ambitious "90-day sprint" to launch a new...more
On April 23, 2024, the U.S. Department of Labor (the “DoL”) released its final rule (“Fiduciary Rule”) titled Retirement Security Rule: Definition of an Investment Advice Fiduciary (an “Investment Advice Fiduciary”), which...more
On May 13, 2024, the U.S. Securities and Exchange Commission’s Division of Investment Management (“SEC”) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint proposal...more
On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets (“OFAC”) amended General License (“GL”) 8N related to Venezuela Sanctions Regulations, 31 CFR part 591....more
Effective April 29, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) introduced a new export license exception to allow the export of medical devices to or within Russia, Belarus and the...more