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SoL Long to Short Limits: The Sequel — A Decade of Recordkeeping and Enforcement

On July 22, 2024, the Department of Treasury, Office of Foreign Assets Control (OFAC) announced a significant planned extension to its recordkeeping requirements, which will increase the retention period from five to ten...more

OFAC Tightens Russia Sanctions; BIS Cracks Down on Diversion

On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including: 1. Expanding the scope of financial sanctions:...more

No More Postcards to OFAC in 2024: Unpacking OFAC’s New Reporting Procedures

On May 10, 2024, The Office of Foreign Assets Control (OFAC) has released a new proposed rule which would make significant changes to OFAC’s standard reporting, record-keeping, and license applications under U.S. sanction...more

Say SoL Long to Short Limits: Doubling Down on the Sanctions Statute of Limitations

Effective April 24, the statute of limitations (“SoL”) under the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) has been extended from five to ten years. It would have been...more

The EU’s 11th Sanctions Package: The Long(er) Arm of the Law

On June 23, 2023, the EU released its 11th package of sanctions on Russia. This package is designed to improve enforcement with new anti-circumvention rules, new trade restrictions, and new designations. The...more

Friday Development: New Sanctions and Export Controls to Address Russia’s Ongoing Aggression in Ukraine (Including the use of...

In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more

Technology to Iran: OFAC Lifts Certain Iran Sanctions In Response to Protests in Iran

After Mahsa Amini was killed in the custody of “Gasht-e-Ershad” or Iran’s Guidance Patrol, commonly referred to as Iran’s morality police, following an arrest for placement of her hijab, protests have erupted throughout Iran...more

U.S. and Allies Impose Additional Severe Costs on Russia for Atrocities in Ukraine (update)

Updated as of April 12, 2022 - It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed...more

U.S. and Allies Impose Additional Severe Costs on Russia for Atrocities in Ukraine

It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed forces, the United States – in...more

Russian Risk: Transactions with Russian Banks and Exports to Russia Create Greatest Exposure Under New U.S. Ukraine-Related...

Updated as of February 25, 2022 - Key Takeaways of OFAC (Treasury) and BIS (Commerce) Actions - Major Russian Banks Blocked from the U.S. Financial System. Six major Russian banks — VEB, Promsvyazbank (PSB), VTB Bank,...more

U.S., UK and EU Sanctions Over Putin’s Recognition of Breakaway Ukraine Regions

U.S. Comprehensive Sanctions Against the DNR and the LNR - Scope: the DNR and LNR - The new EO does not detail which parts of the Donetsk and Luhansk regions[1] are subject to the new U.S. sanctions. It is likely that...more

Counterpunch: China Adopts Landmark Anti-Sanctions Statute to Stop U.S. Sanctions Effects Overseas

On June 10, 2021, China enacted the Anti-Foreign Sanctions Law (“AFSL”), aimed at punishing countries that impose anti-China sanctions and the companies that comply with those sanctions. The law is effective immediately, and...more

The EU – U.S. Sanctions Dilemma: The Advocate General of the European Court of Justice Weighs in

In May 2018 the United States announced the reinstitution of sanctions against Iran that had previously been lifted pursuant to the Joint Comprehensive Plan Action (“JCPOA”). The U.S. sanctions on Iran that were revived...more

U.S. Imposes Sanctions Measures Targeting Myanmar Military Government

On February 1, 2021, the Myanmar military overthrew the country’s democratically elected government and installed an army general as head of state, with a cadre of military officials and their allies running the government. ...more

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