The United States has substantially expanded economic sanctions and export controls targeting Russia and Belarus, imposing new restrictions that could have a major impact on companies with business activities in or relating...more
The 21st Century Peace Through Strength Act became law recently as part of H.R. 815, which also provided aid to Ukraine, Israel and Taiwan. The law contains important sanctions measures that: Extend the statute of...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced two enforcement actions this year. Both reference the Financial Crimes Enforcement Network's (FinCEN) whistleblower program,...more
President Biden issued an executive order on December 22, 2023 targeting evasion of U.S. sanctions on Russia. Executive Order 14,114: Authorizes sanctions on foreign financial institutions (“FFIs”) determined to have...more
The United States has strengthened economic sanctions and export controls targeting Russia, following through on commitments made at a G7 summit this month. The EU and UK also plan to substantially expand measures targeting...more
In light of Russia’s invasion of Ukraine and intensifying strategic competition with China, the U.S. government is prioritizing enforcement of export controls and economic sanctions in unprecedented ways. We expect higher...more
Effective December 5, 2022, a coalition of G7 countries, Australia, and the European Union have generally forbidden service providers to provide certain services relating to the maritime transport of Russia-origin crude oil...more
12/6/2022
/ Australia ,
Economic Sanctions ,
EU ,
Exports ,
G7 ,
General Licenses ,
Maritime Transport ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned the popular decentralized virtual currency mixer Tornado Cash on August 8, 2022, continuing the U.S. government’s efforts to target...more
As part of its continuing response to Russia’s ongoing hostilities in Ukraine, the United States recently imposed additional sanctions and export controls targeting Russia...more
The Financial Crimes Enforcement Network (“FinCEN”) recently issued an advisory urging financial institutions (including certain cryptocurrency businesses) to implement controls to help detect proceeds of foreign public...more
4/27/2022
/ Bribery ,
BSA/AML ,
Cryptocurrency ,
Economic Sanctions ,
Embezzlement ,
Extortion ,
Financial Institutions ,
FinCEN ,
Foreign Official ,
Misappropriation ,
Money Laundering ,
New Guidance ,
Offshore Funds ,
Public Corruption ,
Ransomware ,
Russia ,
Shell Corporations ,
Suspicious Activities ,
Suspicious Activity Reports (SARs)
The United States, the European Union and the United Kingdom recently imposed new Russia-related sanctions in response to Russia’s continued hostilities in Ukraine...more
The United States and its allies continue to ramp up pressure on Russia and Belarus in response to Russia’s continued hostilities in Ukraine. In this alert, we describe the latest export, import, and investment bans and...more
Building on the “first tranche” of sanctions announced on February 22, 2022 described in our prior alert, the United States, the EU, the UK, and their allies have imposed (or announced the imposition of) additional...more
3/1/2022
/ Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Financial Transactions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SWIFT ,
Ukraine ,
Virtual Currency
In response to the Russian government’s recognition of the Donetsk and Luhansk People’s Republics of Ukraine (the “Covered Regions”) as states and deployment of Russian troops to the Covered Regions, the United States and its...more
President Biden issued a new Executive Order 14024 (“E.O. 14024”) on April 15, 2021, expanding sanctions against Russia. E.O. 14024 authorizes, for the first time, U.S. sanctions against Russian technology companies and,...more
4/21/2021
/ Biden Administration ,
Crimea ,
Critical Infrastructure Sectors ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts
In March 2021, three federal agencies promulgated international trade restraints as part of the Biden Administration’s response to alleged mistreatment of Russian opposition leader Alexey Navalny in 2020. Specifically, the...more
3/31/2021
/ Arms Embargo ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
Economic Sanctions ,
Energy Projects ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Infrastructure ,
ITAR ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Trade Restrictions ,
US Trade Policies ,
Vessels
In response to a U.S. government consensus that trade with China involves grave national security risks, the Trump Administration promulgated a broad series of China-directed export controls, economic sanctions and import...more
1/28/2021
/ Biden Administration ,
Blocking Statutes ,
China ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Human Rights ,
Infrastructure ,
Military End Use ,
Regulatory Reform ,
US Trade Policies
Late last week, a Magistrate Judge for the U.S. District Court for the Northern District of California issued an order granting a motion for a nationwide preliminary injunction forbidding implementation of sanctions against...more
9/21/2020
/ China ,
Data Collection ,
Economic Sanctions ,
Executive Orders ,
First Amendment ,
Mobile Apps ,
National Security ,
Preliminary Injunctions ,
Social Media ,
TikTok ,
Trump Administration
Last week, the Department of Commerce took steps to implement sanctions targeting China’s mobile applications WeChat, owned by Tencent Holdings Ltd. (“WeChat Sanctions”), and TikTok, owned by ByteDance Ltd. (“ByteDance”)...more
As noted in our recent alert, President Trump signed into law the Hong Kong Autonomy Act (“HKAA”) on July 14, 2020. On the same day, the President also issued an Executive Order on Hong Kong Normalization (the “Executive...more
Yesterday, after unanimous passage by the U.S. Congress, President Trump signed into law the Hong Kong Autonomy Act (“HKAA”) in retaliation against China for it's “Law on Safeguarding National Security in the Hong Kong...more
The Office of Foreign Assets Control of the U.S. Treasury Department (“OFAC”) issued an extensive Fact Sheet on April 16, 2020 regarding the provision of humanitarian assistance and trade to combat COVID-19 in compliance with...more
4/17/2020
/ Economic Sanctions ,
Executive Orders ,
FEMA ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Humanitarian Assistance ,
Iran Sanctions ,
Medical Supplies ,
Office of Foreign Assets Control (OFAC) ,
Personal Protective Equipment
A recent federal criminal action shows the depth of the U.S. government’s concern about the use of cryptocurrency (or virtual currency) to violate economic sanctions laws and the lengths to which it will go to charge such...more
1/24/2020
/ Anti-Money Laundering ,
Bitcoin Mining ,
BSA/AML ,
CFTC ,
Corruption ,
Cryptocurrency ,
Currency Exchange ,
Digital Currency ,
Economic Sanctions ,
Financial Transactions ,
FinCEN ,
Geo-Blocking ,
Jurisdiction ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Oversight ,
Risk Management ,
Sanction Violations ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Strict Compliance ,
Strict Liability ,
Virtual Currency
With new Iran-related sanctions, the U.S. government is making good on threats to give third-country companies a choice – participate in the U.S. market or participate in the Iranian market.
...more
1/13/2020
/ Aluminum Sales ,
Blocked Person ,
Critical Infrastructure Sectors ,
Economic Sanctions ,
Executive Orders ,
Foreign Corporations ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Steel Industry ,
Trump Administration ,
U.S. Treasury
On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more
1/2/2020
/ Aircraft ,
Aircraft Equipment ,
Aircraft Sales ,
CAATSA ,
Criminal Investigations ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Department of Defense (DOD) ,
Drug & Alcohol Abuse ,
Drug Trafficking ,
Economic Sanctions ,
Energy Policy ,
Energy Projects ,
Entity List ,
Export Administration Regulations (EAR) ,
Exports ,
Financial Transactions ,
Foreign Financial Institutions (FFI) ,
Foreign Persons ,
Foreign Relations ,
Germany ,
Huawei ,
Iran ,
Iran Sanctions ,
National Security ,
Natural Gas ,
NDAA ,
North Korea ,
Oil & Gas ,
Opioid ,
Pain Management ,
Patriot Act ,
Pharmaceutical Industry ,
Pipelines ,
Popular ,
Procurement Guidelines ,
Risk Management ,
Russia ,
Strict Compliance ,
Supply Chain ,
Syria ,
Telecommunications ,
Trump Administration ,
Turkey ,
U.S. Commerce Department ,
United Nations