As the third month of the second Trump administration comes to a close, the lack of any public enforcement action by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctions watchers...more
4/25/2025
/ Corporate Counsel ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Risk Management ,
Russia ,
Settlement ,
Trump Administration ,
Ukraine
2022 was an unprecedented year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). While the sweeping new U.S. sanctions imposed against Russia and Belarus in unparalleled...more
3/2/2023
/ Burma ,
China ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
Human Rights ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
UN Security Council ,
United Nations ,
Venezuela ,
Virtual Currency
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
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
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 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 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
Three weeks ago, France, Germany, and the United Kingdom (the “E3”) created INSTEX SAS (Instrument for Supporting Trade Exchanges, INSTEX), an entity designed to enhance business between the EU and Iran and to serve as a core...more
Executive Summary -
On November 5, 2018, the United States enacted the second of two powerful phases of the “snap-back” of Iran sanctions, re-imposing sanctions that were lifted by the United States in 2016 as a result of...more
On August 6, 2018, President Trump signed an executive order (“New Iran E.O.”) directing the Secretaries of State and the Treasury to re-impose sweeping sanctions on Iran, effecting the policy announced on May 8, 2018, to...more