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OFAC Year-in-Review 2021 Part II – Lessons Learned from OFAC’s 2021 Enforcement Actions

Back in July, we took a look at the enforcement actions for the first half of 2021 issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Today’s post – the second half of our OFAC 2021 Year...more

National Defense Authorization Act – Implications for U.S. Sanctions Programs

In a closely followed and much anticipated action, President Biden signed the National Defense Authorization Act for Fiscal Year 2022 (NDAA) on December 27, 2021 – following its approval by the U.S. Senate and House of...more

Sanctions Legislation Watch: What to Expect from Congress as 2021 Comes to a Close

As we approach year’s end, and the pace of legislative activity ramps up, it remains critical to keep a close eye on the sanctions-related bills currently making their way, at varying speeds, through the U.S. legislative...more

No Surprises, But Fascinating Statistics on the Growth of Sanctions, as Treasury Releases its 2021 Sanctions Review

On October 18, 2021, the U.S. Department of the Treasury (“Treasury”) released its 2021 Sanctions Review (“Sanctions Review” or the “Review”), which includes recommendations for preserving the effectiveness of sanctions...more

Congress Re-Enters the Nord Stream 2 Fight with Amendment to NDAA

In the latest turn of events in the seemingly never-ending political saga of the Nord Stream 2 pipeline, the U.S. House of Representatives (the “House”), via an amendment to the 2022 National Defense Authorization Act...more

Biden Issues Executive Order To Reset And Expand Sanctions On Chinese Military And Surveillance Companies

On June 3, 2021, President Biden issued a new executive order (E.O.), “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China” (E.O. 14032). The E.O. prohibits U.S....more

Senate Republicans Introduce Legislation To Impose Sanctions On Nord Stream 2 Following The Biden Administration’s Waiver

The legal and political skirmishing continued on both sides of the Atlantic in recent weeks over Nord Stream 2, the nearly finished Russian natural gas pipeline that continues to serve as a flash point within Europe and...more

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