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 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
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
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
On Thursday, October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an advisory highlighting potential sanctions risks associated with ransomware payments related to malicious...more
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
7/10/2020
/ Autonomy ,
China ,
Coronavirus/COVID-19 ,
Hong Kong ,
Office of Foreign Assets Control (OFAC) ,
Protests ,
Russia ,
Sanctions ,
SDN List ,
Secretary of State ,
Trump Administration
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
In a much-anticipated and far-reaching action, on May 14, 2020, the U.S. Department of State, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the U.S. Coast Guard issued an advisory (the...more
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
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
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
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
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
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
8/9/2019
/ Blocked Entities ,
Blocked Person ,
CFIUS ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Humanitarian Assistance ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
SDN List ,
Trump Administration ,
Venezuela
On May 2, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published its first-ever Framework for OFAC Compliance Commitments (“Framework”), detailing the essential components of a sanctions...more
With tensions rising in the Persian Gulf, and Iran on the brink of pulling out of portions of the Iran nuclear deal, President Trump issued new Executive Order 13871 last Wednesday, May 8, 2019, imposing sanctions on Iran’s...more
On a bizarre day for sanctions that saw President Trump seemingly take action related to North Korea via tweet – revoke recent measures? scuttle pending ones? – the U.S. Treasury Department’s Office of Foreign Assets Control...more
UPDATE: Two days after we issued our Top 20 sanctions compliance lessons from recent OFAC enforcement cases, OFAC issued an unprecedented enforcement one-two punch. On February 7, 2019, OFAC settled an enforcement case with...more
Last Thursday, January 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued its first enforcement action of 2019, a fascinating case involving false eyelashes that teaches that virtually any...more
In what was perhaps an inevitable escalation, on Monday, January 28, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on Venezuelan state-owned oil and gas company Petróleos de...more
On Sunday, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it lifted sanctions on three entities associated with Russian oligarch Oleg Deripaska, including the second-largest aluminum...more
On December 19, 2018, Treasury’s Office of Foreign Assets Control (OFAC) took two complementary actions involving U.S. sanctions related to Russia. The first was notifying Congress of the office’s intent to terminate...more
EDITOR’S NOTE -
In like a lion, out like a lamb—it works for weather; does it work for new administrations? We’ll have to wait and see. We’ll have to wait and see about the length of CFPB Director Richard Cordray’s...more
3/20/2017
/ Anti-Money Laundering ,
Arbitration Agreements ,
Bank Fraud ,
Bank Holding Company Act ,
Banking Sector ,
Banks ,
Civil Monetary Penalty ,
Consumer Financial Protection Bureau (CFPB) ,
Criminal Prosecution ,
Data Security ,
Distributed Ledger Technology (DLT) ,
Fair Credit Reporting Act (FCRA) ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Forfeiture ,
NIST ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Opt-In ,
Overdraft Fees ,
Preemption ,
Shaw v United States ,
Student Loans ,
TCPA ,
TLAC ,
True Lender