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Executive Order Terminates Syria Sanctions, Directs Actions to Remove Other Trade Restrictions

President Donald Trump issued an Executive Order (the EO) on June 30, 2025, terminating the U.S. government's Syria sanctions program and directing other actions that, if finalized, will revoke the vast majority of U.S. trade...more

Trump Administration Provides Significant Sanctions Relief to Syria

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on May 23, 2025, announced a significant relaxation of the comprehensive economic sanctions imposed on Syria through the issuance of General...more

President Trump Announces Intent to Lift Syria Sanctions

During an investment forum in Riyadh, Saudi Arabia, on May 13, 2025, President Donald Trump announced his intent to lift sanctions on Syria, stating that sanctions relief will "give them a chance at greatness."...more

Trump Threatens Retaliatory Measures vs. Latin American Countries Refusing Repatriation Flights

President Donald Trump on Jan. 20, 2025, issued various immigration-related Executive Orders (EOs) and presidential actions that could have an immediate and lasting impact on Latin American countries. President Trump's...more

Trump Administration Rescinds Certain Actions by the Previous Administration to Ease Cuba Sanctions

Within hours after taking office on Jan. 20, 2025, U.S. President Donald Trump signed an omnibus executive order revoking 78 executive actions by the previous administration, dating back to 2021. Among them, President Trump...more

U.S. Announces Steps to Ease Cuba Sanctions

Besides certain expansions on remittances in 2022, the White House, on Jan. 14, 2025, issued a statement announcing President Joe Biden's plans to relax sanctions on Cuba through a series of broad measures aimed at improving...more

OFAC Amends Regulations to Support Cuban People, Independent Private-Sector Entrepreneurs

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR), 31 CFR Part 515, to promote internet freedom in Cuba, support independent Cuban private-sector...more

OFAC Revokes General License 44 Related to Venezuela's Oil and Gas Sector

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License 44A (GL 44A) on April 17, 2024, replacing and superseding General License 44 (GL 44). On Oct. 18, 2023, OFAC suspended...more

New Tri-Seal Compliance Note Issued to Non-U.S. Persons

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), U.S. Department of Commerce's Bureau of Industry and Security (BIS) and U.S. Department of Justice (DOJ) on March 6, 2024, issued a Tri-Seal...more

Tri-Seal Compliance Note Issued on Export Controls, Sanctions Violations Self-Disclosures

The U.S. Department of Justice (DOJ), Department of Commerce's Bureau of Industry and Security (BIS) and Department of the Treasury's Office of Foreign Assets Control (OFAC) on July 26, 2023, issued a Tri-Seal Compliance Note...more

United States Imposes Expanded Sanctions and Export Controls on Russia

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) took a number of actions under the Export Administration Regulations (EAR) on May 19, 2023. Here are some of the key U.S. export control actions...more

OFAC Updates U.S. Oil Price Cap Policy Against Russia

As an update to an earlier Holland & Knight alert on the same topic, the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) has published another determination pursuant to Executive Order 14071 expanding...more

OFAC Increases Civil Monetary Penalties for 2023

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is increasing each civil monetary penalty within its jurisdiction for 2023 by 7.7 percent. The increases came into effect on Jan. 13, 2023.1 Note...more

Restraining the Kraken: Another Crypto Company Under OFAC Scrutiny

The U.S. Department of the Treasury's Office of Foreign Asset Control (OFAC) on Nov. 28, 2022, announced a more than $362,000 settlement with Payward Inc. d/b/a Kraken (Kraken), a Delaware-incorporated company that offers...more

OFAC Places Price Cap on Maritime Services Related to Russian Oil

The U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) on Nov. 21, 2022, published a determination pursuant to E.O. 14071 prohibiting U.S. persons from providing certain services related to the maritime...more

OFAC Provides Relief for Certain Aviation and Maritime Vessels

The U.S. Department of the Treasury's Office of Foreign Asset Control (OFAC) recently issued two general licenses related to aviation and maritime safety. OFAC issued Russia-related General License 40C (GL 40C), Civil...more

Crypto Company Comes Under OFAC Scrutiny

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 11, 2022, announced a more than $24.28 million settlement with Bittrex Inc. (Bittrex), a Bellevue, Washington-based company that offers...more

Biden Administration Eases Some Trump-Era Cuba Restrictions

The U.S. Department of State announced on May 16, 2022, a series of measures aimed at supporting the Cuban people and independent Cuban entrepreneurs and loosening Trump-era restrictions that largely isolated the island and...more

United States Imposes Additional Sanctions on Nicaragua

The Office of Foreign Assets Control (OFAC) on Sept. 4, 2019, promulgated regulations expanding the application of Executive Order 13851 ("Blocking Property of Certain Persons Contributing to the Situation in Nicaragua")...more

Cuba Policy in Flux: Seven Unanswered Questions - Unresolved Issues Remain Regarding Trump Administration's Announcement Not to...

• Effective May 2, 2019, the Trump Administration will not continue the waiver against lawsuits under Title III of the Cuban Liberty and Democratic Solidarity (LIBERTAD) Act of 1996, also known as the Helms-Burton Act. •...more

Ambassador Bolton Warns of Potential U.S. Secondary Sanctions Against Venezuela - Non-U.S. Entities Transacting with Certain...

• National Security Advisor Ambassador John Bolton issued a statement threatening sanctions against non-U.S. banks for facilitating illegitimate transactions with certain Venezuelan individuals and entities. • This...more

Treasury Designates Additional Maduro Officials, Provides Additional Guidance

• The U.S. Department of the Treasury's (Treasury) Office of Foreign Assets Control (OFAC) has designated five officials affiliated with the regime of Nicolas Maduro pursuant to Executive Order 13850 (E.O. 13850), including...more

OFAC Designates Petroleos de Venezuela S.A.; U.S. Expands Sanctions on Venezuelan Government - Additional Measures Also Taken...

• Pursuant to Executive Order 13850 (E.O. 13850), the U.S. Department of the Treasury's (Treasury) Office of Foreign Assets Control (OFAC) designated Petroleos de Venezuela, S.A. (PdVSA), effectively blocking PdVSA's property...more

U.S. Revokes Certain Authorizations Related to Iran, Issues "Wind-Down" Regulations

• The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) revoked certain Iran-related "general licenses" that allowed U.S. and U.S.-owned foreign entities to engage in certain transactions and...more

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