On May 23, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License 25 (GL 25), effectively lifting most sanctions imposed under the Syrian Sanctions Regulations (SSR) (31...more
On April 2 — labeled “Liberation Day” by President Trump — the Trump administration is set to add a new sanctions-like boost to its tariff strategy, with a threat to impose unprecedented “secondary tariffs” of 25% on “all...more
3/28/2025
/ Corporate Counsel ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Infrastructure ,
Mexico ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Regulatory Oversight ,
Secondary Sanctions ,
Secretary of Commerce ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
Venezuela
On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more
3/26/2025
/ Anti-Money Laundering ,
BSA/AML ,
Corporate Counsel ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
EU ,
Final Rules ,
Financial Institutions ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Regulatory Reform ,
Regulatory Requirements ,
Terrorist Financing Regulations ,
Trading with the Enemy Act ,
U.S. Treasury
On March 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) allowed General License (GL) 8L under the Russian Harmful Foreign Activities Sanctions Regulations to expire. As a result, broad OFAC...more
3/14/2025
/ Banks ,
Biden Administration ,
Biofuel ,
Economic Sanctions ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Prohibited Transactions ,
Russia ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
U.S. Treasury
The Trump administration continues to ramp up sanctions on Venezuela and Yemen's Houthis, while sending mixed signals about its intentions with respect to Russia. We provide brief updates on these three areas, following up...more
3/11/2025
/ Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Regulatory Reform ,
Russia ,
Terrorist Organizations ,
Trump Administration ,
U.S. Treasury ,
US Trade Policies ,
Venezuela ,
Yemen
On February 20, 2025, the U.S. Departments of State and the Treasury designated eight Latin American drug trafficking cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), in...more
2/25/2025
/ Anti-Terrorism Financing ,
Cartels ,
Cooperative Compliance Regime ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
SDN List ,
Terrorist Financing Regulations ,
Trafficking ,
Trump Administration
Days before President Biden leaves the White House, the U.S. government has delivered a major blow against Russia. On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced...more
1/17/2025
/ Biden Administration ,
Economic Sanctions ,
Energy Sector ,
Export Controls ,
Foreign Policy ,
Infrastructure ,
Liquid Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
U.S. Treasury
On December 18, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 1B (Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue...more
1/9/2025
/ Blocked Person ,
Compliance ,
Economic Sanctions ,
Energy Sector ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Russia ,
SDN List ,
U.S. Treasury
On November 27, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned 21 high-ranking Venezuelan officials aligned with Nicolás Maduro. These sanctions, issued under Executive Order...more
U.S. sanctions laws present complex conflicts with state insurance laws. While state laws govern the timely payment of claims and other insurance practices, U.S. sanctions administered by the U.S. Department of the Treasury’s...more
On November 7, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 5Q ("Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5...more
On November 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated Gazprombank, over 50 internationally connected Russian banks, more than 40 Russian securities registrars, and 15...more
On November 13, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended several insurance-related Frequently Asked Questions (“FAQs”) (61, 62, 63, 64, 65, 68, 69, 102, 103, and 104) as...more
On October 31, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released guidance to the maritime shipping industry to help stakeholders identify and avoid sanctions evasion tactics. The...more
On October 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Frequently Asked Question (“FAQ”) 1197 on securities held at the National Settlement Depository (“NSD”) in connection...more
On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an Interim Final Rule amending its Reporting, Procedures, and Penalties Regulations under 31 C.F.R. Part 501. This...more
On September 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 8 alongside amendments to various Frequently Asked Questions (“FAQs”) in connection with the...more
On September 24, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three frequently asked questions (“FAQs”) that provide guidance to U.S. companies regarding the Determination...more
Russian Political Disinformation Efforts -
On September 4, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) designated 10 individuals and two entities as specially designated nationals...more
Iran and Syria Sanctions and Embargos On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued updated guidance to remind maritime support service providers that the...more
9/25/2024
/ Economic Sanctions ,
Embargo ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Syria
On September 5, 2024, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) released General License (“GL”) 108 (“Authorizing Limited Safety and Environmental Transactions Involving Certain Blocked...more
On August 27, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced amendments to two key FAQs (FAQs 736 and 757) concerning the Cuban Assets Control Regulations (“CACR”). These FAQs...more
On August 23, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 103 ("Authorizing Transactions Related to Imports of Certain Diamond Jewelry Prohibited by...more
The U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) on (i) July 10, 2024, extended General License (“GL”) 13J (“Authorizing Certain Administrative Transactions Prohibited by Directive 4 under...more
On July 23, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) issued a new reporting requirement following the enactment of the Rebuilding Economic Prosperity and Opportunity for Ukrainians...more