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
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 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
• 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
• 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
• 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
• 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
In this episode, Akin Gump public law and policy senior advisor and former U.S. Rep. Ileana Ros-Lehtinen and international trade partner Nnedi Ifudu discuss U.S. sanctions on Venezuela.
Among the topics covered:
• the...more
4/24/2019
/ Banking Sector ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Member State ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Steel Industry ,
Trump Administration ,
Venezuela ,
WTO
• On April 8, 2019, the U.S. government announced its intention to designate the Islamic Revolutionary Guards Corps (IRGC) as a Foreign Terrorist Organization, effective April 15, 2019. This unprecedented action will result...more
4/15/2019
/ Antiterrorism and Effective Death Penalty Act (AEDPA) ,
CAATSA ,
Foreign Policy ,
Iran ,
Iran Sanctions ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Terrorist Threats ,
Trump Administration ,
U.S. Treasury
• OFAC recently added a Moscow-based Russian-Venezuelan joint venture bank, Evrofinance Mosnarbank (“Evrofinance”), to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) for engaging in sanctions...more
3/29/2019
/ Banking Sector ,
Blocked Person ,
Economic Sanctions ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Joint Venture ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Trump Administration ,
Venezuela
• On January 28, 2019, OFAC added the Venezuelan state-owned oil and natural gas company PdVSA to its SDN List.
• As a result, U.S. persons are generally prohibited from engaging in transactions with PdVSA and entities that...more
2/6/2019
/ Blocked Person ,
Bonds ,
Capital Markets ,
Debt-Equity ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Securities Transactions ,
State-Owned Enterprises ,
Trump Administration ,
Venezuela
• On November 28, 2018, OFAC designated two Iran-based individuals who helped exchange cryptocurrency (bitcoin) into fiat currency on behalf of alleged ransomware perpetrators who targeted U.S. businesses and municipal...more
1/11/2019
/ Bitcoin ,
Blocked Person ,
Corporate Counsel ,
Crypto Exchanges ,
Cryptocurrency ,
Cyber Attacks ,
Cyber Crimes ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Digital Currency ,
Digital Wallets ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
SDN List ,
U.S. Treasury
• On November 27, 2018, the Trump administration issued an executive order establishing a new sanctions regime against Nicaragua.
• This occurs as the Trump Administration has articulated an approach to Latin America in...more
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
11/27/2018
/ Aircraft ,
Blocking Statutes ,
Cross-Border Transactions ,
Economic Sanctions ,
EU ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Humanitarian Assistance ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
SDN List ,
Special Purpose Vehicles ,
SWIFT ,
Trade Policy ,
Trump Administration ,
Vessels
• On October 11, 2018, FinCEN released an advisory to help U.S. financial institutions better detect potentially illicit transactions related to Iran.
• The advisory describes how Iran attempts to access the international...more
10/23/2018
/ Advisory Opinions ,
AML/CFT ,
Banks ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
International Finance ,
International Relations ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
Money Services Business ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SDN List ,
Virtual Currency
• On September 20, 2018, for the first time, the Trump administration imposed sanctions on a non-U.S. entity and its director for engaging in “significant transactions” with a Russian defense sector company included on the...more
9/26/2018
/ Blocked Person ,
CAATSA ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Intelligence Services ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Secondary Sanctions ,
Suppliers ,
Trump Administration
• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more
8/17/2018
/ Blocking Statutes ,
Economic Sanctions ,
EU ,
Executive Orders ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Winding Down ,
Withdrawal
• On May 22, 2018, OFAC issued General License 15, authorizing U.S. persons to engage in specified transactions related to maintenance or wind-down of operations, contracts or other agreements involving GAZ Group or any...more
• On May 1, 2018, OFAC issued General License 13A authorizing the divestment or transfer of certain debt, equity or other holdings issued by EN+ Group, GAZ Group or United Company RUSAL PLC, as well as entities in which such...more
Today, OFAC issued General License 14, authorizing U.S. persons to engage in specified transactions related to maintenance or wind down of operations, contracts or other agreements involving RUSAL until October 23, 2018,...more