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U.S. Sanctions Roundup – October & November 2024

The Department of the Treasury's Office of Foreign Assets Control (“OFAC”) was active in October and November 2024. After issuing an Updated Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors on...more

OFAC Publishes Updated Maritime Oil Industry Advisory

On October 21, 2024, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) issued an Updated Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors (“Updated Advisory”). OFAC...more

OFAC Issues Guidance Concerning Statute of Limitations Extension

On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50 (the “Act”). By doing so, the statute of limitations (“SoL”) for violations, both criminal and civil, of IEEPA...more

Developments in U.S. International Trade Laws Since the Start of 2023 and What to Expect for the Rest of 2024

Throughout 2023 and early 2024, we continue to witness deepening geopolitical and economic divides globally. The U.S. and its allies (most significantly the EU and the G7), spurred on by Russia’s war in Ukraine, continue to...more

OFAC Issues Two Determinations Prohibiting Dealings in Certain Metals of Russian Origin; Extends General License Allowing Payment...

On April 12, 2024, in coordination with the United Kingdom, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two new Determinations (collectively, the “Determinations”) that together prohibit...more

Enforcement of U.S. Trade Sanctions and Export Controls in 2023 and What to Expect In 2024

This is the tenth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. Our previous post, "Health Care Fraud Enforcement in 2024," can be found here....more

Biden Administration Threatens Foreign Financial Institutions With Secondary Sanctions for Involvement in Certain Transactions...

On December 22, 2023, President Biden issued a new Executive Order affecting foreign financial institutions and those importing certain goods into the U.S. In addition, OFAC provided related new and revised FAQs, as well...more

Department of State, OFAC, and BIS Issue Sweeping Additional Sanctions on Russia, While EU Proposes Tightening Russian Oil Price...

U.S. authorities have been active in November 2023, reinforcing and expanding sanctions targeting Russia's war effort in Ukraine. Multiple agencies added sanctions targeting entities involved in Russia's military supply...more

OFAC Publishes Maritime Oil Industry Advisory and Makes Example of Shipping Companies and Vessels Who Violated G7’s Price Cap...

On October 12, 2023, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) published a Maritime Oil Industry Advisory (“Advisory”)—together with the so-called Price Cap Coalition (“Coalition”), consisting...more

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Regarding Self-Disclosure of Potential Sanctions Violations

On July 26, 2023, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), and the U.S. Department of the Treasury’s Office of...more

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