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
2/9/2022
/ Cloud Storage ,
Corporate Counsel ,
Digital Currency ,
Foreign Exchanges ,
Foreign Subsidiaries ,
Geolocation ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanctions ,
SDN List ,
U.S. Treasury ,
UK ,
Virtual Currency
2021 was a year of transition in the United States and for the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s year, while busy, was far different from 2020, as the Biden Administration’s...more
2/8/2022
/ Biden Administration ,
Burma ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Forced Labor ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Iran ,
NDAA ,
NGOs ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
U.S. Treasury
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
11/9/2021
/ China ,
Corruption ,
Forced Labor ,
Foreign Policy ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
U.S. Treasury
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
As close observers of the Committee on Foreign Investment in the United States (“CFIUS” or “Committee”) are aware, the Committee has the authority to recommend that the President of the United States block a transaction on...more
As peak summer holiday season approaches, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continues to remind the private sector of the importance of strict economic sanctions compliance. OFAC...more
7/15/2021
/ Corporate Counsel ,
Department of Justice (DOJ) ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Exchanges ,
ITSR ,
Moneygram ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
U.S. Treasury
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
On February 11, 2021, President Biden issued Executive Order 14014 of February 10, 2021, “Blocking Property With Respect to the Situation in Burma” (“E.O. 14014”), the first sanctions-related E.O. of his new administration,...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 October 30, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published an advisory highlighting potential sanctions risks arising from dealings in “high-value artwork” (with “particular...more
On Wednesday, October 14, 2020, the U.S. Department of State (“State”) submitted a report to the U.S. Congress, as required under section 5(a) of the Hong Kong Autonomy Act (“HKAA”), identifying foreign persons materially...more
10/19/2020
/ China ,
Coronavirus/COVID-19 ,
Foreign Financial Institutions (FFI) ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
SDN List ,
Trump Administration ,
U.S. Treasury ,
US Department of State
On Thursday, October 8, 2020, U.S. Secretary of the Treasury Steven Mnuchin identified the Iranian financial sector as subject to the sectoral sanctions of Executive Order (“E.O.”) 13902, escalating the formidable Trump...more
Parties to investment transactions involving U.S. businesses engaged in “critical technologies” activities will soon be subject to modified requirements for mandatory filings to the Committee on Foreign Investment in the...more
9/18/2020
/ CFIUS ,
Corporate Counsel ,
Critical Infrastructure Sectors ,
Export Administration Regulations (EAR) ,
Export Controls ,
Final Rules ,
FIRRMA ,
Foreign Investment ,
ITAR ,
NAICS ,
National Security ,
U.S. Commerce Department ,
U.S. Treasury
Much of the world’s focus is on the COVID-19 pandemic, and rightfully so, but sanctions regulators also have their gazes fixed on another issue: the maritime industry. On May 14 2020, we saw the U.S. Departments of State and...more
8/7/2020
/ Charter ,
Coast Guard ,
Compliance ,
Cryptocurrency ,
Customs and Border Protection ,
Cyber Attacks ,
Due Diligence ,
Economic Sanctions ,
Exports ,
Imports ,
Insurance Industry ,
Maritime Transport ,
New Guidance ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Ports ,
Risk Assessment ,
Risk Management ,
Risk Mitigation ,
Sanction Violations ,
Shipping ,
U.S. Treasury ,
UK ,
Unions ,
Vessels
On June 5, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued four new frequently asked questions (“FAQs”) that define key terms used in secondary sanctions added to the Iran sanctions...more
The U.S. Department of the Treasury (“Treasury”) announced that on Friday, May 1, 2020, the first-ever filing fees will become effective for joint voluntary notices submitted to the Committee on Foreign Investment in the...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
The U.S. Department of the Treasury (Treasury) has released final regulations to implement the Foreign Investment Risk Review Modernization Act (FIRRMA), expanding the jurisdiction of the Committee on Foreign Investment in...more
This is the third in our multipart series of alerts addressing proposed regulations published in the Federal Register on September 24, 2019, for the Committee on Foreign Investment in the United States (CFIUS) to implement...more
After more than a year of anticipation, the U.S. Department of the Treasury (“Treasury”) has released proposed regulations to implement the Foreign Investment Risk Review Modernization Act (FIRRMA). These proposed regulations...more
After more than a year of anticipation, the U.S. Department of the Treasury (“Treasury”) has released proposed regulations to implement the Foreign Investment Risk Review Modernization Act (FIRRMA). These proposed regulations...more
As many life sciences companies and investors are aware, the U.S. Department of the Treasury (“Treasury”) recently announced a new “pilot program” for the Committee on Foreign Investment in the United States (“CFIUS”)...more
As many life sciences companies and investors are aware, the U.S. Department of the Treasury (“Treasury”) recently announced a new “pilot program” for the Committee on Foreign Investment in the United States (“CFIUS”)...more