On August 5, 2019, President Donald Trump signed Executive Order 13884, Executive Order Blocking Property of the Government of Venezuela (EO 13884). EO 13884 is designed to further increase pressure on the Nicolás Maduro...more
8/7/2019
/ Blocked Person ,
Citgo ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
Trump Administration ,
U.S. Treasury ,
Venezuela
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more
7/29/2019
/ Anti-Money Laundering ,
BSA/AML ,
Cuba ,
Customer Due Diligence (CDD) ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
FinCEN ,
Human Trafficking ,
Iran ,
Magnitsky Act ,
Nicaragua ,
North Korea ,
Russia ,
Sudan ,
Trump Administration ,
Venezuela ,
Virtual Currency
On March 27, 2019, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with US-based Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd....more
4/2/2019
/ Black & Decker ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Foreign Subsidiaries ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Settlement ,
Subsidiaries
After decades in which the Foreign Agents Registration Act (FARA) received relatively little attention, a confluence of recent events has given the statute newfound prominence. Together, these developments compound the...more
3/11/2019
/ Advisory Opinions ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Exemptions ,
Foreign Agents ,
Foreign Agents Registration Act (FARA) ,
Foreign Governments ,
Foreign Nationals ,
Lobbying ,
Lobbying Disclosure Act ,
National Security ,
Recordkeeping Requirements ,
Reporting Requirements
Yesterday, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) pursuant to Executive Order 13850, adding the state-owned Venezuelan oil company to its...more
On November 28, the Treasury Department sanctioned two Iran-based individuals for exchanging bitcoin into Iranian rials on behalf of malicious cyber actors involved in the SamSam ransomware scheme. Notably, this action marks...more
12/3/2018
/ Bitcoin ,
Crypto Exchanges ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Iran ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
SDN List ,
U.S. Treasury
On November 5, 2018, the United States took steps to complete the U.S. withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”), under which the United States – along with its partners in the P5+1 – had previously...more
11/9/2018
/ Blocked Entities ,
Economic Sanctions ,
EU ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
P5+1 Nations ,
SDN List ,
Trump Administration ,
UN Security Council
President Donald Trump issued an Executive Order “Reimposing Certain Sanctions with Respect to Iran” (“New Iran E.O.”) on August 6, 2018, authorizing the re-imposition – or “snap-back” – of various sanctions against dealings...more
On August 1, 2018, the US Department of Commerce Bureau of Industry and Security (BIS) published a Federal Register notice stating that the US government had identified 44 Chinese companies as acting contrary to US national...more
On Friday, May 18, the EU Commission launched the formal process to reactivate a 1996 trade defense law in response to the US withdrawal from the Joint Comprehensive Plan of Action (JCPOA) on Iran's nuclear program. Once...more
5/23/2018
/ Blocking Statutes ,
China ,
EU ,
European Commission ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Russia ,
Trade Relations ,
Trump Administration
On Tuesday, May 8, President Trump announced that the United States would end its participation in the Joint Comprehensive Plan of Action (JCPOA), signed by the Permanent Five Members of the Security Council plus Germany...more
On December 20, 2017, President Trump issued a new Executive Order (EO) targeting corruption and human rights abuses around the world.
The EO implements last year's Global Magnitsky Human Rights Accountability Act (the...more
On November 9, 2017, the US Departments of the Treasury and Commerce implemented President Trump's June 2017 National Security Presidential Memorandum (NSPM) that was designed to tighten restrictions on individual travel to...more
Over the past several years, as North Korea has increased the capability of its nuclear and ballistic missile program, there has been a steady increase in sanctions pressure against North Korea by the United States and the...more
On August 24, 2017, the Trump Administration significantly expanded sanctions against the Government of Venezuela, including state-owned oil company Petroleos de Venezuela, S.A. (PdVSA). These latest sanctions reflect...more
On July 27, the US Senate passed the Countering America's Adversaries Through Sanctions Act (CAATSA), a comprehensive sanctions bill that expands US sanctions against three countries: Russia, Iran, and North Korea. The...more
On June 16, 2017, President Trump announced new sanctions restrictions under the US embargo against Cuba. Although US policy since 2014 has been to normalize US-Cuba relations and liberalize trade with Cuba, President Trump...more
Over the past year, regulators continued to actively examine compliance, introduce new and heightened requirements, recalibrate global priorities, and aggressively pursue enforcement. This report reviews recent trends and...more
4/28/2017
/ BSA/AML ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
FATF ,
Financial Services Committee ,
FinCEN ,
Iran ,
NYDFS ,
Russia ,
Securities and Exchange Commission (SEC)
On April 18, 2017, the State Department certified to Congress that Iran was in compliance with its obligations under the Joint Comprehensive Plan of Action (JCPOA) between the United States, Iran, and the P5+1 nations. It...more
New Iran Designations -
On Friday, the US Treasury Department's Office of Foreign Assets Control (OFAC) designated 25 individuals and entities under Executive Orders 13382 and 13224 for their roles in procuring...more
On January 13, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a general license that authorizes all transactions with Sudan that were previously prohibited by the Sudanese Sanctions...more
President Obama amended a previously-issued executive order designed to address cyber-enabled activities yesterday in response to “Russia's cyber activities [that] were intended to influence the election, erode faith in U.S....more
President-elect Donald Trump is promising major changes to US trade policy that, if implemented, will significantly impact US and foreign companies that compete in the global market, and that could particularly impact those...more
On October 17, the US Departments of Commerce and the Treasury announced the sixth round of eased sanctions and export controls designed to bolster trade between the United States and Cuba. The amendments by the Bureau of...more
The United Nations Security Council (“UNSC”) approved a Resolution last week imposing new sanctions against North Korea in response to its recent nuclear and missile tests. This UNSC action follows the enactment of the North...more