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
2/9/2022
/ Cloud Storage ,
Corporate Counsel ,
Digital Currency ,
Foreign Exchanges ,
Foreign Subsidiaries ,
Geolocation ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanctions ,
SDN List ,
U.S. Treasury ,
UK ,
Virtual Currency
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
2/8/2022
/ Biden Administration ,
Burma ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Forced Labor ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Iran ,
NDAA ,
NGOs ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
U.S. Treasury
As we approach year’s end, and the pace of legislative activity ramps up, it remains critical to keep a close eye on the sanctions-related bills currently making their way, at varying speeds, through the U.S. legislative...more
11/9/2021
/ China ,
Corruption ,
Forced Labor ,
Foreign Policy ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
U.S. Treasury
In the latest turn of events in the seemingly never-ending political saga of the Nord Stream 2 pipeline, the U.S. House of Representatives (the “House”), via an amendment to the 2022 National Defense Authorization Act...more
10/7/2021
/ CAATSA ,
Foreign Entities ,
Germany ,
Joe Biden ,
National Interest Waiver ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
Sanctions ,
Trump Administration ,
US State Departments
As peak summer holiday season approaches, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continues to remind the private sector of the importance of strict economic sanctions compliance. OFAC...more
7/15/2021
/ Corporate Counsel ,
Department of Justice (DOJ) ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Exchanges ,
ITSR ,
Moneygram ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
U.S. Treasury
As we previously wrote in our OFAC 2020 Year in Review, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) saw a drop in enforcement activity in 2020, likely due to the massive year it had in 2019 and...more
2/18/2021
/ Audits ,
Citizenship ,
Compliance ,
Corporate Counsel ,
Enforcement Actions ,
Foreign Subsidiaries ,
Information Technology ,
Licenses ,
Nexus ,
Office of Foreign Assets Control (OFAC) ,
Remediation ,
Sanctions
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
2/16/2021
/ China ,
Corporate Counsel ,
Cuban Assets Control Regulations (CACR) ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Financial Institutions (FFI) ,
Iran Sanctions ,
Maritime Transport ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Pentagon ,
Pipelines ,
Popular ,
Ransomware ,
Russia ,
SDN List ,
Trump Administration
Former US President Trump during his term of office only a week, before the release of its 13959 No. Executive Order ( "Executive Order") has been modified . The previous executive order prohibits Americans from investing in...more
With just one week remaining in his term, President Trump amended Executive Order (“EO”) 13959, which prohibits U.S. persons from investing in the securities of Chinese Military Companies (“CMCs”), to continue his aggressive...more
On December 28, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued five new frequently asked questions (“FAQs”) that clarify the scope of Executive Order (“E.O.”) 13959, the basis for OFAC’s...more
Over the past summer, prompted by a bipartisan Congressional letter identifying a two‑decade‑old statute as an unused tool in confronting China’s strategy of “Military-Civilian Fusion,” the U.S. Department of Defense (“DOD”)...more
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
10/19/2020
/ China ,
Coronavirus/COVID-19 ,
Foreign Financial Institutions (FFI) ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
SDN List ,
Trump Administration ,
U.S. Treasury ,
US Department of State