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
5/30/2024
/ Amended Regulation ,
Bank Accounts ,
Banking Sector ,
Biden Administration ,
Blocked Person ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Development ,
Entrepreneurs ,
Financial Services Industry ,
Foreign Nationals ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Private Sector ,
SDN List
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
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
3/15/2024
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Extraterritoriality Rules ,
FinCEN ,
Joint Policy Statements ,
Office of Foreign Assets Control (OFAC) ,
Self-Disclosure Requirements
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
8/2/2023
/ Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Authority ,
Export Controls ,
Exports ,
Iran ,
Joint Policy Statements ,
Joint Statements ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Self-Reporting
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
5/25/2023
/ Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Globally Harmonized System ,
Iran ,
Military End Use ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Tariffs ,
Ukraine
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
2/8/2023
/ Australia ,
Biden Administration ,
Crude Oil ,
Economic Sanctions ,
EU ,
Executive Orders ,
Exports ,
G7 ,
Maritime Transport ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Petroleum ,
Russia ,
Tariffs ,
Ukraine
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
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
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
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
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
10/25/2022
/ Compliance ,
Cooperation ,
Crypto Exchanges ,
Cryptocurrency ,
Digital Assets ,
Economic Sanctions ,
Enforcement Actions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Settlement ,
Virtual Currency
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
5/23/2022
/ Biden Administration ,
Cannabis Products ,
Consulate ,
Corporate Counsel ,
Cuba ,
Federal Aviation Administration (FAA) ,
Foreign Relations ,
Human Rights ,
Obama Administration ,
Office of Foreign Assets Control (OFAC) ,
Small Business ,
Trade Restrictions ,
Travel Restrictions ,
Trump Administration ,
U.S. Embassies ,
US Department of State ,
Visas
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
• President Donald Trump saying at the recent G20 Summit in Japan that American companies could keep selling products to Huawei Technologies Co. Ltd. (Huawei) was another installment in the drama surrounding the Chinese tech...more
7/17/2019
/ Bureau of Industry and Security (BIS) ,
China ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Adversaries ,
Foreign Policy ,
General Licenses ,
Huawei ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Sanction Violations ,
Technology Sector ,
Telecommunications ,
Trade Relations ,
Trade Wars ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
• 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
4/26/2019
/ Civil Liability ,
Cuba ,
Extraterritoriality Rules ,
Foreign Nationals ,
International Travel ,
Office of Foreign Assets Control (OFAC) ,
Personal Jurisdiction ,
Trafficking ,
Trump Administration ,
US State Departments ,
WTO
• 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
3/14/2019
/ Banking Sector ,
Blocked Entities ,
Cross-Border Transactions ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Venezuela
• 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
• 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
1/31/2019
/ Banking Sector ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Petroleum ,
SDN List ,
Trump Administration ,
Venezuela
• 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
• President Donald Trump has issued a new Executive Order expanding existing sanctions against the government of Venezuela and its instrumentalities, including the state-owned oil company, Petróleos de Venezuela (PdVSA).
...more
• The United States is withdrawing from the multilateral nuclear accord with Iran known as the Joint Comprehensive Plan of Action (JCPOA).
• The U.S. sanctions waived by President Barack Obama under the JCPOA will be...more
The Trump Administration rounded out the year with two sanctions-related actions: The first involved creating a new program regarding human rights abusers and global corruption; the second involved adding several individuals...more
1/3/2018
/ Bad Actors ,
Corruption ,
Economic Sanctions ,
Executive Orders ,
Foreign Nationals ,
Human Rights ,
Magnitsky Act ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trump Administration
• The U.S. Department of State issued public guidance on sanctions with respect to 39 named entities related to Russia's defense and intelligence sectors. This guidance is issued under Section 231 of the Countering America's...more
11/10/2017
/ Arctic Drilling ,
CAATSA ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Secretary of State ,
Secretary of the Treasury ,
Shale Gas ,
SSI List ,
Trump Administration ,
US Department of State
On July 20, 2017, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $2 million civil monetary penalty against Exxon Mobil Corp., including its U.S. subsidiaries ExxonMobil Development...more
8/3/2017
/ Administrative Procedure Act ,
Arbitrary and Capricious ,
Civil Monetary Penalty ,
Due Process ,
Economic Sanctions ,
Exxon Mobil ,
Fifth Amendment ,
Fines ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Reckless Disregard ,
Russia ,
Sanction Violations ,
SDN List ,
Ukraine
Before leaving office, former President Barack Obama signed Executive Order (E.O.) 13761 on Jan. 13, 2017, in response to "positive actions" by the Government of Sudan. E.O. 13761 establishes a basis for complete revocation...more
1/27/2017
/ Agricultural Sector ,
Aircraft ,
Airlines ,
Barack Obama ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Railroads ,
Revocation ,
Sudan ,
Technology