On April 29, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published General License (“GL”) 8I related to the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR Part...more
On December 6, 2023, and February 24, 2024, the G7 Leaders announced their intention to diminish Russia’s earnings from metal exports. On April 12, 2024, in collaboration with the United Kingdom the United States introduced...more
An April 17, 2024, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) issued General License (“GL”) 44A (“Authorizing the Wind Down of Transactions Related to Oil or Gas Sector Operations in...more
The U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) introduced a significant final rule on March 20, 2024, intending to fortify national security. This rule amendment enhances restrictions under the Export...more
The Office of Antiboycott Compliance (“OAC”) within the U.S. Department of the Treasury’s Bureau of Industry and Security (“BIS”) is charged with administering and enforcing the Anti-Boycott Act of 2018, Part II of the Export...more
On March 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended and reissued the Global Magnitsky Sanctions Regulations (the “Regulations”) to further the Global Magnitsky Human...more
Money laundering generally refers to financial transactions in which criminals, including terrorist organizations, attempt to disguise the proceeds, sources, or nature of their illicit activities. Money laundering facilitates...more
On February 28, 2024, by Executive Order (“EO”) 14117, President Biden issued “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern.” The EO directs...more
On March 5, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of Justice (“DOJ”) issued a...more
On February 29, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets (“OFAC”) amended General License (“GL”) 45B related to Venezuela Sanctions Regulations, 31 CFR part 591. Subsequently, on March 1, 2024,...more
On February 13, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) proposed a new rule that would require federal investment advisers to add Bank Secrecy Act (“BSA”) type anti-money...more
In response to the second anniversary of Russia’s illegal war against Ukraine and the death of political opposition leader and anti-corruption activist Aleksey Navalny, the United States Department of the Treasury’s Office of...more
On January 29, 2024, the Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a civil penalty of $153,175 against a global rail technology manufacturer headquartered in Pittsburgh, Pennsylvania (the...more
On February 1, 2024 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a comprehensive "Oil Price Cap Compliance and Enforcement Alert" (the “Alert”) to bolster enforcement of the Russian...more
On January 29, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) revoked General License (“GL”) 43 and issued GL 43A (“Authorizing the Wind Down of Transactions Involving CVG Compania...more
Public Companies are Exempt, But . . .
Public companies have an exemption from the filing requirements under the new Corporate Transparency Act (CTA) reporting rules. The public company exemption applies to companies that...more
On January 18, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated Hennesea Holdings Limited (“Hennesea”) and multiple vessels owned by Hennesea to the Specially Designated...more
On January 16, 2024, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) issued General License (“GL”) 5N (Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5...more
On December 22, 2023, President Biden signed the Foreign Extortion Prevention Act (“FEPA”) into law as part of the fiscal year 2024 National Defense Authorization Act, sweeping in a new era in U.S. anti-corruption measures....more
On December 22, 2023, President Biden ordered new U.S. sanctions against Russia by issuing Executive Order (“EO”) 14114 (“Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities”). EO 14114 amends...more
On December 22, 2023, President Biden issued new Executive Order (“EO”) 14114, amending EO 14024 and EO 14068. The new EO grants the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) authority to...more
On December 20, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General Licenses (“GL”) 81 and GL 82 under the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR...more
On December 12, 2023, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State (“DOS”) sanctioned more than 250 individuals and entities by adding them to the List of...more
On December 6, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) unveiled three pivotal rules that amend the Export Administration Regulations (“EAR”). These rules mark a crucial step in a...more
On December 5, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added several persons to the List of Specially Designated Nationals and Blocked Persons (“SDNs”) and issued General...more