On December 1, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General Licenses (“GL”) 78 which authorizes limited safety and environmental transactions involving certain...more
On November 16, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets (“OFAC”) amended General License (“GL”) 8M and 45A, and issued four new FAQs (FAQ 1141-1144) related to Venezuela Sanctions Regulations, 31...more
On November 16, 2023, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) sanctioned three UAE-based entities and blocked three vessels that engaged Price Cap Coalition service providers to...more
On October 13, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a new rule to update general authorizations for Samsung and SK Hynix, two semiconductor companies headquartered in the...more
On September 26, 2023, in response to the escalating crisis in Ukraine resulting from Russian aggression, Australia, Canada, New Zealand, the United Kingdom, and the United States (the “Export Enforcement Five” or “E5”)...more
On November 9, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 76A to clarify that the GL applies to “Public Joint Stock Company Saint Petersburg...more
On October 31, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published Directive 1 under Executive Order 14014 (the “Directive”) that will, effective as of December 15, 2023, prohibit...more
On November 2, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published General License (“GL”) 13G, GL 74, GL 75, and GL 76 related to the Russian Harmful Foreign Activities Sanctions...more
On October 12, 2023, U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) issued General License (“GL”) 73 authorizing limited safety and environmental transactions involving certain persons and vessels...more
On September 8, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released its Financial Trend Analysis (“FTA”). The FTA details FinCEN’s analysis of suspicious activity reports...more
On October 25, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published General Licenses (“GL”) 8H related to the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR Part...more
In light of the recent agreement on an electoral roadmap between Venezuela’s Maduro regime and the Unitary Platform, and as a show of support for the Venezuelan people, the U.S. Department of the Treasury’s Office of Foreign...more
On September 14, 2023, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) issued two Russia–related general licenses...more
Expanding upon our initial QuickStudy published on August 15, 2023, this QuickStudy explores certain implications of President Biden’s August 9, 2023 Executive Order (“EO”) that introduced a new “Outbound Investment Program”...more
On August 8, 2023, the Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License 13F Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024...more
On August 9, 2023, the Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Belarus General License 8 "Authorizing the Wind Down of Transactions Involving Joint Stock Company Byelorussian Steel Works...more
On August 9, 2023 the U.S. President Biden issued Executive Order “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (“Executive Order”)....more
On July 26, 2023, the U.S. Department of Justice (“DOJ”), the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a...more
On July 20, 2023 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added nearly 120 individuals, entities, and vessels to the Specially Designated Nationals (“SDN”) List pursuant to Executive...more
On July 19, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 5L pursuant to the Venezuela Sanctions Regulations, 31 CFR Part 591 (“VSR”) which further delays...more
On July 10, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 40B pursuant to the Venezuela Sanctions Regulations, 31 CFR Part 591 (“VSR”)....more
On June 28, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the UK’s Office of Financial Sanctions Implementation of His Majesty’s Treasury (“OFSI”), released a joint fact sheet on...more
On May 19, 2023, the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) issued additional export control restrictions aimed at further degrading the Russian Federation’s capacity to wage its aggression...more
In conjunction with the G7 Summit in Japan, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) introduced additional economic sanctions on May 19, 2023, with the aim of further limiting the...more
We are updating our March 6, 2023 QuickStudy that discussed the new statutory exemption under section 15(b)(13) of the Securities Exchange Act of 1934 from broker registration that allows unregistered M&A advisers to provide...more