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OFAC Amends Cuba Sanctions, Loosening Restrictions and Fully Implementing Biden Administration’s Cuba Policy

On May 28, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced amendments to 31 C.F.R. Part 515, the Cuban Assets Control Regulations (CACR), expanding access to certain financial and...more

U.S. Agencies Caution Foreign-Based Persons on Extraterritorial Reach of U.S. Sanctions and Export Control Regulations

On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more

Enhanced Global Russian Sanctions and Export Controls to Counter Circumvention

On May 19, in response to Russia’s ongoing invasion of Ukraine, the United States, in coordination with allies and partners, announced new sanctions restrictions and export controls targeting Russia’s evasion networks,...more

The Emergence of a Global Russia Sanctions Enforcement Regime

The year since Russia’s invasion of Ukraine has been marked by the development of a multi-jurisdictional, multi-agency sanctions regime in the United States, the United Kingdom and the European Union. Although coordination...more

OFAC Imposes New Sanctions to Thwart Ransomware

On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more

President Biden Signs New Executive Order Escalating US Sanctions Against Russia

On April 15, 2021, President Biden signed a new executive order, Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation, escalating US sanctions against the Russian...more

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