On December 28, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued five new frequently asked questions (“FAQs”) that clarify the scope of Executive Order (“E.O.”) 13959, the basis for OFAC’s...more
Over the past summer, prompted by a bipartisan Congressional letter identifying a two‑decade‑old statute as an unused tool in confronting China’s strategy of “Military-Civilian Fusion,” the U.S. Department of Defense (“DOD”)...more
On February 18, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) added Rosneft Trading S.A. (“Rosneft Trading”) and its president to the agency’s List of Specially Designated Nationals and...more
Over the past few days, we here at MoFo’s National Security Practice Group have outlined the extraordinary pace of activity that the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) maintained in 2019 as...more
As we mentioned in the first part of our U.S. Sanctions Year in Review series, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) had an extraordinarily busy year in 2019, and its enforcement activity...more
As we enter 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) may need time to catch its breath after an exceptionally busy year. 2019 showed us that the Trump Administration continues to rely on...more
On October 23, 2019, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced it was removing three Turkish government ministers and two Turkish government ministries from its list of Specially Designated...more
With tensions rising in the Persian Gulf, and Iran on the brink of pulling out of portions of the Iran nuclear deal, President Trump issued new Executive Order 13871 last Wednesday, May 8, 2019, imposing sanctions on Iran’s...more
On a bizarre day for sanctions that saw President Trump seemingly take action related to North Korea via tweet – revoke recent measures? scuttle pending ones? – the U.S. Treasury Department’s Office of Foreign Assets Control...more
UPDATE: Two days after we issued our Top 20 sanctions compliance lessons from recent OFAC enforcement cases, OFAC issued an unprecedented enforcement one-two punch. On February 7, 2019, OFAC settled an enforcement case with...more
Last Thursday, January 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued its first enforcement action of 2019, a fascinating case involving false eyelashes that teaches that virtually any...more
In what was perhaps an inevitable escalation, on Monday, January 28, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on Venezuelan state-owned oil and gas company Petróleos de...more
On Sunday, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it lifted sanctions on three entities associated with Russian oligarch Oleg Deripaska, including the second-largest aluminum...more
On April 6, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) added 38 new designees to its list of Specially Designated Nationals and Blocked Persons (“SDN List”) related to Russia pursuant to...more
The announcement by the International Atomic Energy Agency on January 16, 2016, that the Government of Iran has satisfied its commitments under the Joint Comprehensive Plan of Action (“JCPOA”), has triggered “Implementation...more
The Treasury Department’s Office of Foreign Assets Control (“OFAC”) has issued its first set of amendments to the Cuban Assets Control Regulations (“CACR”) to begin implementing a major policy shift in United States–Cuba...more