Key Points -
On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took action to relax certain U.S. sanctions on Venezuela in response to the signing of an electoral roadmap...more
Introduction -
In 2022, the United States, European Union (EU) and United Kingdom, along with a significant number of other partners and allies, imposed an unprecedented number of economic, financial and trade sanctions...more
Key Points -
The United States, European Union, United Kingdom and other U.S. allies are currently considering a range of severe economic measures against Russia to impose in the event of a Russian military incursion into...more
1/31/2022
/ Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
Sanctions ,
SDN List ,
Ukraine
- On February 18, 2020, OFAC designated Rosneft Trading, S.A. (Rosneft Trading), a subsidiary of Russia-based Open Joint-Stock Company Rosneft Oil Company (Rosneft Oil Company), and its president, Didier Casimiro, on the SDN...more
2/21/2020
/ Blocked Person ,
Crude Oil ,
Economic Sanctions ,
Energy Sector ,
Export Controls ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Venezuela
• A new Executive Order signed October 14, 2019, authorizes U.S. sanctions related to the military conflict between Turkey and Syria, providing broad authority to impose sanctions against Turkish government agencies,...more
• On June 21, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued and put into effect an Interim Final Rule (Interim Rule) that requires all U.S. persons and persons subject to U.S....more
• President Trump issued a new Executive Order (EO) on May 8, 2019—exactly one year after the Trump administration withdrew from the Iran nuclear deal—that widened the scope of existing sanctions targeting the Iranian...more
6/4/2019
/ Aluminum Sales ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Steel Industry ,
Trump Administration
• On April 8, 2019, the U.S. government announced its intention to designate the Islamic Revolutionary Guards Corps (IRGC) as a Foreign Terrorist Organization, effective April 15, 2019. This unprecedented action will result...more
4/15/2019
/ Antiterrorism and Effective Death Penalty Act (AEDPA) ,
CAATSA ,
Foreign Policy ,
Iran ,
Iran Sanctions ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Terrorist Threats ,
Trump Administration ,
U.S. Treasury
• On January 28, 2019, OFAC added the Venezuelan state-owned oil and natural gas company PdVSA to its SDN List.
• As a result, U.S. persons are generally prohibited from engaging in transactions with PdVSA and entities that...more
2/6/2019
/ Blocked Person ,
Bonds ,
Capital Markets ,
Debt-Equity ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Securities Transactions ,
State-Owned Enterprises ,
Trump Administration ,
Venezuela
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
11/27/2018
/ Aircraft ,
Blocking Statutes ,
Cross-Border Transactions ,
Economic Sanctions ,
EU ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Humanitarian Assistance ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
SDN List ,
Special Purpose Vehicles ,
SWIFT ,
Trade Policy ,
Trump Administration ,
Vessels
• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more
8/17/2018
/ Blocking Statutes ,
Economic Sanctions ,
EU ,
Executive Orders ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Winding Down ,
Withdrawal
• On May 22, 2018, OFAC issued General License 15, authorizing U.S. persons to engage in specified transactions related to maintenance or wind-down of operations, contracts or other agreements involving GAZ Group or any...more
• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more
5/10/2018
/ Controlled Foreign Corporations ,
Economic Sanctions ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trade Policy ,
Trump Administration
• On May 1, 2018, OFAC issued General License 13A authorizing the divestment or transfer of certain debt, equity or other holdings issued by EN+ Group, GAZ Group or United Company RUSAL PLC, as well as entities in which such...more
Today, OFAC issued General License 14, authorizing U.S. persons to engage in specified transactions related to maintenance or wind down of operations, contracts or other agreements involving RUSAL until October 23, 2018,...more
• On April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed seven prominent Russian businessmen, 12 companies, 17 senior Russian government officials, and a state-owned Russian...more
4/9/2018
/ Banking Sector ,
Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Government Officials ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Trump Administration ,
U.S. Treasury
• Effective October 13, 2017, President Trump declined to provide certification that the JCPOA is in the United States’ national interest. Following this “decertification,” the U.S. Congress has 60 days in which to introduce...more
11/2/2017
/ Anti-Terrorism Financing ,
Decertify ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Nuclear Agreement Review Act of 2015 (INARA) ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Legislative Amendments ,
Members of Congress ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Proposed Legislation ,
SDN List ,
Sunset Provisions ,
Trump Administration ,
U.S. Treasury
Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more
10/13/2017
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Commodities ,
Department of Defense (DOD) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secretary of State ,
Sudan ,
Trade Restrictions ,
Trump Administration ,
TSRA
On July 27, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the civil settlement with CSE TransTel Pte. Ltd. (“TransTel”) and CSE Global Limited (“CSE Global”) in the amount of...more
8/12/2017
/ Economic Sanctions ,
Enforcement Actions ,
Financial Transactions ,
Iran ,
Iran Sanctions ,
Jurisdiction ,
Non-US Entities ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Sanction Violations ,
SDN List ,
Section 203 ,
Settlement
On August 2, 2017, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act of 2017 (Pub. Law. No. 115-44, H.R. 3364) (the “Act”), which significantly expands economic sanctions against...more
8/9/2017
/ Anti-Corruption ,
Anti-Terrorism Financing ,
Arms Embargo ,
Congressional Override ,
Cyber Sanctions ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Oil & Gas ,
Pipelines ,
Privatization ,
Russia ,
SDN List ,
SSI List ,
State-Owned Enterprises ,
Syria ,
Trade Restrictions ,
Trump Administration
Key Points -
- The U.S. Department of the Treasury’s Office of Foreign Assets Control has added 25 new entities and individuals to its Specially Designated Nationals List, including some located in China, Lebanon,...more
On October 7, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published new guidance clarifying (a) circumstances under which non-U.S. financial institutions (FFIs) may engage in U.S. dollar...more
If you only read one thing...
- The Hizballah Financial Sanctions Regulations (HFSR) are intended to disrupt Hizballah’s global logistics and financial network by providing a new basis of secondary sanctions...more
On July 14, 2015, Iran and the P5+1 countries (China, France, Germany, Russia, the United Kingdom and the United States), with the High Representative of the European Union for Foreign Affairs and Security Policy, finalized...more
7/16/2015
/ Aircraft Equipment ,
Airlines ,
EU ,
Foreign Trade Regulations ,
Imports ,
Inspections ,
International Atomic Energy Agency ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Member State ,
Multinationals ,
P5+1 Nations ,
SDN List ,
UN Security Council ,
United Nations