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Lessons Learned From OFAC’s 2020 Enforcement Actions

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

Biden Administration Issues Executive Order Re-Imposing Sanctions On Burma

On February 11, 2021, President Biden issued Executive Order 14014 of February 10, 2021, “Blocking Property With Respect to the Situation in Burma” (“E.O. 14014”), the first sanctions-related E.O. of his new administration,...more

Defense Bill Aims Additional Sanctions At Turkey, Russia, And China

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

OFAC Issues Advisory Highlighting Art Trade No “Goghs”

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

Trump Administration Broadens Sanctions On Russian Pipeline Projects (Again)

On October 20, 2020, the U.S. Department of State (“State”) broadened, yet again, the scope of sanctions applicable to Russian energy export pipeline projects, most notably the Nord Stream 2 pipeline, a nearly finished...more

Hong Kong In The Crosshairs: Secretary Of State Submits Hong Kong Autonomy Act Report To Congress, Paving Path For Secondary...

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

Pay At Your Own Risk: OFAC Issues Advisory On Potential Sanctions Risks Stemming From Ransomware Payments

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

Back In Business? OFAC Issues New General Licenses For Companies Doing Business With GAZ Group

Given the magnitude of current events gripping the country and the world, many otherwise noteworthy governmental actions are passing largely unnoticed. One such under-the-radar action occurred on July 22, 2020, when the U.S....more

Sanctions Followed: A New Round Of Sanctions Against China And Russia

As the new crown virus is spreading and there have been many demonstrations that "blacks are also fate," the US Congress has increased its work during the election year, threatening to strengthen sanctions against China and...more

Sanctions Spree: New Round Of Sanctions Against China And Russia

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

Trump Threatens Sanctions Against The International Criminal Court

The United States has for decades utilized its economic clout to pursue sanctions against rogue governments and regimes, terrorists, narcotics traffickers, and human rights abusers. Now, with roughly half a year left in his...more

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