On September 11, 2024, OFAC announced its Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years. The Interim Final Rule (IFR) was published in the Federal Register on September 13, 2024. Public...more
9/16/2024
/ CFIUS ,
Corporate Counsel ,
Cuba ,
Export Controls ,
Interim Final Rules (IFR) ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
OMB ,
Recordkeeping Requirements ,
Reporting Requirements ,
TWEA
On June 12, 2024, the United States took several hard-hitting sanctions- and export control-related actions intended to intensify pressure on the Russian government and hamper Russia’s ability to continue to support its war...more
6/19/2024
/ Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Financial Institutions (FFI) ,
General Licenses ,
Information Technology ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Secondary Sanctions ,
Software ,
Supply Chain ,
U.S. Commerce Department
On March 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its first enforcement case of the year and its first ever involving dealings with a Russian designated for sanctions...more
3/25/2024
/ Corporate Counsel ,
Cuban Assets Control Regulations (CACR) ,
Due Diligence ,
Economic Sanctions ,
Enforcement ,
Executive Orders ,
Export Controls ,
Foreign Narcotics Kingpin Sanctions Regulations (FNKSR) ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Russia ,
Securities Transactions ,
U.S. Treasury
On March 6, 2024, the U.S. Departments of Commerce, Justice, and the Treasury issued a Tri-Seal Compliance Note (Compliance Note) stressing the need for non-U.S. persons to comply with U.S. sanctions and export controls. The...more
As Russia’s war in Ukraine passes the one-year mark, and the battles on the ground move forward with escalating levels of ferocity, governments around the world continue to coordinate and respond with increasingly severe...more
3/3/2023
/ Asset Freeze ,
Bureau of Industry and Security (BIS) ,
Central Bank of Russia ,
Economic Sanctions ,
EU ,
Export Controls ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
UK ,
Ukraine
After months of negotiations, Congress revealed the compromise version of the National Defense Authorization Act for Fiscal Year 2023 (NDAA) on December 6, 2022. The bill, viewed as a “must-pass” piece of legislation because...more
12/15/2022
/ Burma ,
China ,
Department of Defense (DOD) ,
Drug Trafficking ,
Economic Sanctions ,
Export Controls ,
Financial Institutions ,
Foreign Investment ,
Human Rights ,
Iran ,
NDAA ,
Popular ,
Russia ,
Semiconductors ,
Supply Chain
As Russia’s war in Ukraine stretches into its tenth month, governments around the world continue to coordinate and respond with increasingly severe sanctions and export controls....more
12/7/2022
/ Crude Oil ,
Economic Sanctions ,
EU ,
Export Controls ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Reporting Requirements ,
Russia ,
UK ,
Ukraine
As Russia’s bloody invasion of Ukraine nears the end of its second month, with regular reports of human rights violations, possible chemical weapons attacks, and head of state musings regarding whether this campaign amounts...more
4/18/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Markets ,
Foreign Relations ,
Japan ,
Most-Favored Nations ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Trade Relations ,
UK ,
Ukraine
As Russia’s brutal invasion of Ukraine stretches on into its second month, the United States, European Union, United Kingdom, and other global allies have continued to pour additional funding and arms into Ukraine while...more
3/23/2022
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
EU ,
Export Controls ,
Funding ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SWIFT ,
UK ,
Ukraine ,
US Department of State
After less than a week of a full-scale war between Russia and Ukraine, the post-Cold War global architecture appears irrevocably shattered, as Western nations line up to offer support and military and economic aid to Ukraine...more
3/1/2022
/ Airspace ,
Asset Freeze ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
G7 ,
Popular ,
Russia ,
SWIFT ,
UK ,
Ukraine ,
United States
In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“DOJ” or the...more
10/15/2021
/ Cryptocurrency ,
Department of Justice (DOJ) ,
DPA ,
Enforcement Actions ,
Export Controls ,
ITAR ,
Military Service Members ,
National Security ,
Non-Prosecution Agreements ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Sanctions ,
Self-Disclosure Requirements ,
United Arab Emirates (UAE) ,
US Department of State ,
Virtual Currency
On April 29, 2021, the U.S. Department of Justice’s National Security Division and the U.S. Attorney’s Office for the District of Massachusetts (collectively, “DOJ”) announced that DOJ entered into a precedent-setting...more
On April 15, 2021, following discussions just days earlier of a potential summit between President Biden and Russian President Putin and as Russian troops amassed along the Ukrainian border, the Biden Administration issued...more
4/20/2021
/ Biden Administration ,
Blocked Person ,
CBW Act ,
Cybersecurity ,
Defense Sector ,
Espionage ,
Executive Orders ,
Export Controls ,
Foreign Interference in US Elections ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts ,
Technology Sector ,
Ukraine ,
Vladimir Putin
One of the widest-ranging bills of the U.S. Congress’s legislative year, the National Defense Authorization Act for Fiscal Year 2021 (NDAA), is nearing the finish line as both the House and Senate overwhelmingly approved the...more
12/15/2020
/ CAATSA ,
China ,
Export Controls ,
Hong Kong ,
NATO ,
NDAA ,
Pentagon ,
Pipelines ,
Russia ,
Sanctions ,
Trump Administration ,
Turkey ,
US Department of State
On December 13, 2019, the Department of Justice’s National Security Division (“NSD”) announced a revised policy to encourage voluntary self-disclosures (“VSDs”) of criminal violations of export control and sanctions laws. The...more
As it nears the end of the calendar and legislative year, Congress is preparing to take long-awaited action to kill Russia’s Nord Stream 2 and TurkStream natural gas pipeline projects – months before Nord Stream 2’s...more
As another sign of the escalating tensions between the United States and China, in addition to the long-running trade war, China this week suspended visits to Hong Kong by the U.S. military and vowed to impose sanctions on a...more
As another sign of the escalating tensions between the United States and China, in addition to the long-running trade war, China this week suspended visits to Hong Kong by the U.S. military and vowed to impose sanctions on a...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
On October 14, President Trump issued an Executive order (“E.O.”) imposing sanctions on Turkey in response to Turkey’s military offensive in northern Syria. New E.O. 13894 authorizes the U.S. Departments of State and the...more
As part of the 18th anniversary of the September 11 attacks earlier this month, the Trump Administration effectively declared the old adage that “one person’s terrorist is another person’s freedom fighter” does not apply with...more
Nearly a quarter century after its passage, the Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996 – commonly known as Helms-Burton, after its sponsors – was expected to revive a significant number of old disputes...more
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has a well-earned reputation in the sanctions bar for ruining weekends. The agency responsible for implementing and enforcing U.S. economic sanctions has...more
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
Back in February, we told you about the Defending American Security from Kremlin Aggression Act, or “DASKA,” a bipartisan effort to impose new sanctions on Russia. Interest in action against the Kremlin has only increased...more