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OFAC Issues Additional Ransomware Guidance and Designates Virtual Currency Exchange

The U.S. Treasury Department has issued an updated ransomware advisory that highlights sanctions risks associated with ransomware payments and details proactive steps companies can take to mitigate these risks....more

United States Imposes New Sanctions on Russia

The Situation: On April 15, 2021, the United States issued a new executive order and related directive imposing additional sanctions on Russia that target dealings in Russian sovereign debt, the technology and defense sectors...more

Biden Administration Imposes Sanctions on Burma Following Military Coup

As part of the U.S. government response, the Department of the Treasury imposes sanctions on certain Burmese persons, and the Department of Commerce heightens export restrictions relating to Burma. In response to the...more

OFAC Guidance on Ransomware Payments Highlights Sanctions Violations Risk

The Situation: In an October 1, 2020, Advisory, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") warned that companies that make or facilitate ransomware payments to threat actors who are...more

U.S. Customs and Border Protection Expands Ban on Products With Suspect Ties to Forced Labor

The Situation: Companies are facing increased pressure by U.S. Customs and Border Protection ("CBP") and other federal agencies to demonstrate that goods imported into the United States were produced without the use of forced...more

U.S. Imposes Sanctions on Turkish Officials, Ministries in Response to Syrian Offensive

The Situation: In response to events in Syria and in the face of strong Congressional pressure to act, President Trump introduced sanctions targeting Turkey. The Result: Although the President indicated that a ceasefire...more

President Trump Expands Sanctions Targeting Maduro Regime - "Embargo" order blocks property of Government of Venezuela and...

On August 5, 2019, President Trump signed Executive Order 13884 ("E.O. 13884") blocking the property of the Government of Venezuela and authorizing sanctions against a range of additional persons. In connection with E.O....more

OFAC Dramatically Expands Reporting Obligations

Ambiguous, undefined terms create uncertainty and confusion, including whether owned or controlled subsidiaries of U.S. companies outside the United States are subject to this reporting requirement. On June 21, the...more

Trump Administration Imposes Further Sanctions on Venezuela, Nicaragua and Cuba; Opens Helms-Burton Act Floodgate

The Situation: On April 17, 2019, the Trump Administration announced additional sanctions targeting the so-called "troika of tyranny" – Venezuela and its key regional allies, Nicaragua and Cuba. These sanctions notably...more

Impact of U.S. Withdrawal from the Iran Nuclear Deal

The Situation: On Tuesday, May 8, 2018, President Trump announced that the United States has withdrawn from the Iran Nuclear Deal and will fully reimpose its suspended sanctions targeting Iran. The Result: All currently...more

United States' Withdrawal From "Iran Deal" Will Reimpose Sanctions

On May 8, 2018, President Trump announced that the United States would cease participating in the Joint Comprehensive Plan of Action ("JCPOA"), commonly known as the Iran Deal. This will reimpose, by no later than November 5,...more

U.S. Sanctions Imposed on Russian Individuals, Associated Entities and Government Officials

The Situation: The Trump Administration has imposed sanctions against a number of high-profile Russian individuals and entities by adding them to the Specially Designated Nationals and Blocked Persons ("SDN") List. The...more

Trump Administration Imposes Venezuelan Digital Currency Sanctions

On March 19, 2018, President Trump signed an Executive Order prohibiting U.S. persons and anyone within the United States from engaging in "transactions related to, [the] provision of financing for, and other dealings in ......more

With Mugabe's Departure, Should Foreign Investors Reconsider Zimbabwe?

The Situation: In November 2017, Robert Mugabe, the only leader Zimbabwe had known in 37 years, was ousted from power. The Development: Will this change in leadership usher in a new era of good governance and economic...more

United States Revokes Sanctions on Sudan; Some Restrictions Remain in Place

On October 6, 2017, the United States announced that, effective October 12, 2017, it will substantially revoke sanctions on Sudan and the Government of Sudan in recognition of the Government of Sudan's sustained positive...more

Trump Administration Imposes Targeted Financial Sanctions on Venezuela

On August 24, 2017, President Donald Trump issued an Executive Order imposing new sanctions intended to restrict financing connected to the Government of Venezuela. These sanctions supplement existing sanctions imposed by the...more

President Trump Signs New Sanctions Legislation into Law

On August 2, 2017, President Trump signed the "Countering America's Adversaries Through Sanctions Act" ("Act") into law. The Act, which codifies and strengthens sanctions against Russia and expands sanctions against Iran and...more

President Trump Revises U.S. Policy on Cuba

On June 16, 2017, President Trump announced revisions to U.S. policy toward engagement with Cuba and a limited rollback of certain sanctions relief provided by the Obama Administration....more

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