Key Points - On May 10, 2024, OFAC issued an IFR that would amend its Reporting, Procedures and Penalties Regulations (RPPR) at 31 C.F.R. Part 501 to, among other things, modify certain reporting requirements pertaining to...more
In February 2024, the U.S. Department of the Treasury issued its 2024 Investment Adviser Risk Assessment, which explains that there are “several illicit finance threats involving investment advisers,” including that...more
5/17/2024
/ AML/CFT ,
Customer Identification Program (CIP) ,
Exempt Reporting Advisers (ERAs) ,
FinCEN ,
Investment Adviser ,
Notice of Proposed Rulemaking (NOPR) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury ,
Venture Capital
While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more
5/1/2024
/ Department of Justice (DOJ) ,
Drug Trafficking ,
Economic Sanctions ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Sanction Violations ,
Statute of Limitations ,
TWEA
Key Points - On April 17, 2024, based on a determination by the U.S. government that Nicolás Maduro and his representatives “have not fully met the commitments made” with respect to upcoming Venezuelan elections, the U.S....more
Key Points -
On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took action to relax certain U.S. sanctions on Venezuela in response to the signing of an electoral roadmap...more
Introduction -
In 2022, the United States, European Union (EU) and United Kingdom, along with a significant number of other partners and allies, imposed an unprecedented number of economic, financial and trade sanctions...more
Key Points -
The United States, European Union, United Kingdom and other U.S. allies are currently considering a range of severe economic measures against Russia to impose in the event of a Russian military incursion into...more
1/31/2022
/ Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
Sanctions ,
SDN List ,
Ukraine
On October 18, 2021, the U.S. Treasury Department released a long awaited report on its first of its kind “top to bottom” review of U.S. economic and financial sanctions. The report does not make or recommend any immediate or...more
On June 3, 2021, President Biden issued Executive Order 14032 (Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China) (“CMIC EO”) that modifies the Trump-era...more
Key Points
- On February 11, 2021, in the first deployment of sanctions since assuming office, President Biden issued EO 14014, authorizing sanctions against members of the Burmese military and related parties responsible...more
The U.S. government has recently imposed controls pertaining to “Communist Chinese Military Companies” (CCMCs or “1237 entities”); Chinese “Military End Users” (MEUs); and Chinese “Military-Intelligence End Users” (MIEUs)....more
Key Points
- On November 12, 2020, President Trump issued a new EO prohibiting U.S. persons from engaging in transactions in publicly traded securities of certain CCMCs, or any securities that are derivative of, or are...more
1/4/2021
/ China ,
Department of Defense (DOD) ,
Derivatives ,
Executive Orders ,
Financial Instruments ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Private Equity ,
Publicly-Traded Companies ,
SDN List ,
Trade Relations ,
Trump Administration ,
US Trade Policies
- On July 1, the Departments of Commerce, Homeland Security, State, and the Treasury issued a joint advisory on the “Risks and Considerations for Businesses with Supply Chain Exposure to Entities Engaged in Forced Labor and...more
7/10/2020
/ China ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Federal Contractors ,
Financial Institutions ,
Forced Labor ,
Human Rights ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Risk Mitigation ,
Supply Chain
- On May 14, 2020, OFAC, the Department of State and the U.S. Coast Guard jointly released guidance for persons involved in the maritime industry regarding common deceptive shipping practices used to subvert U.S. and United...more
6/4/2020
/ Economic Sanctions ,
Energy Sector ,
Enforcement Actions ,
Exports ,
Imports ,
Iran ,
Maritime Transport ,
Metals ,
New Guidance ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Shipping ,
Supply Chain ,
Syria ,
Unfair or Deceptive Trade Practices ,
Vessels
- On February 18, 2020, OFAC designated Rosneft Trading, S.A. (Rosneft Trading), a subsidiary of Russia-based Open Joint-Stock Company Rosneft Oil Company (Rosneft Oil Company), and its president, Didier Casimiro, on the SDN...more
2/21/2020
/ Blocked Person ,
Crude Oil ,
Economic Sanctions ,
Energy Sector ,
Export Controls ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Venezuela
Medical device and diagnostics companies and laboratories should anticipate significant legal, regulatory and market changes in 2020 that will have a lasting impact on the industry. From revisions to how the government...more
1/8/2020
/ Acquisitions ,
Artificial Intelligence ,
Biotechnology ,
Centers for Medicare & Medicaid Services (CMS) ,
CFIUS ,
Department of Health and Human Services (HHS) ,
Digital Health ,
EU ,
Export Controls ,
Food and Drug Administration (FDA) ,
General Data Protection Regulation (GDPR) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Innovation ,
Life Sciences ,
Machine Learning ,
Medical Devices ,
Mergers ,
Office of Foreign Assets Control (OFAC) ,
Patent-Eligible Subject Matter ,
Pharmaceutical Industry ,
Popular ,
Section 101 ,
USPTO
• On October 23, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed the two Turkish government ministries and three ministers that it added to its Specially Designated Nationals and...more
10/25/2019
/ Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Syria ,
Trump Administration ,
Turkey
• A new Executive Order signed October 14, 2019, authorizes U.S. sanctions related to the military conflict between Turkey and Syria, providing broad authority to impose sanctions against Turkish government agencies,...more
On September 9, 2019, the Trump administration implemented additional U.S. sanctions on Cuba by restricting personal remittances to Cuba and eliminating authorization for U.S. banks to process “U-turn” transactions involving...more
9/11/2019
/ Banking Sector ,
Cross-Border Transactions ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Foreign Policy ,
Fund Transfers ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Personal Remittance Caps ,
Trump Administration ,
U-Turn Transactions ,
U.S. Treasury
• In a further escalation of U.S. sanctions on Venezuela in support of its efforts to oust the regime of Nicolás Maduro, on August 5, 2019, the Trump administration imposed comprehensive sanctions on the Government of...more
8/19/2019
/ Banking Sector ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration ,
Venezuela
• The U.S. Department of State and the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) have imposed three new sanctions on Russia:
o Effective August 26, 2019, U.S. banks (as defined below) are...more
8/14/2019
/ Biological-Weapons ,
CBW Act ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Financial Institutions (FFI) ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sovereign Debt ,
Trump Administration
• On June 21, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued and put into effect an Interim Final Rule (Interim Rule) that requires all U.S. persons and persons subject to U.S....more
In a June 4 announcement, the Trump administration further ratcheted up U.S. sanctions and export controls against Cuba by prohibiting group “people-to-people” travel to Cuba and the use of noncommercial aircraft and...more
6/6/2019
/ Aircraft ,
Airline Passengers ,
Bureau of Industry and Security (BIS) ,
Cuba ,
Export Administration Regulations (EAR) ,
Federal Aviation Administration (FAA) ,
Foreign Relations ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Trump Administration ,
Vessels
• President Trump issued a new Executive Order (EO) on May 8, 2019—exactly one year after the Trump administration withdrew from the Iran nuclear deal—that widened the scope of existing sanctions targeting the Iranian...more
6/4/2019
/ Aluminum Sales ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Steel Industry ,
Trump Administration
• The U.S. Department of the Treasury's Office of Foreign Assets Controls (OFAC) recently published guidance that describes the framework for an effective Sanctions Compliance Program (SCP). In its guidance, OFAC makes clear...more
5/30/2019
/ Civil Monetary Penalty ,
Compliance ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Internal Controls ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Risk Mitigation ,
Sanctions ,
Senior Managers ,
U.S. Treasury ,
Voluntary Disclosure