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Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments

Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more

OFAC Revokes General Authorization for Venezuelan Oil and Gas Sector But Permits Limited Wind-Down Transactions

Broad authorizations permitting dealings in Venezuela’s oil and gas sector came to an end on April 17, 2024, when the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) terminated General...more

New Sanctions on Russia Mark Two-Year Anniversary of Ukraine Invasion

On February 23, 2024, the Biden Administration announced new sanctions targeting a number of different sectors of the Russian economy, Russian government officials and financial institutions, entities suspected of sanctions...more

OFAC Issues New General Licenses for Venezuela, Suspending Sanctions in Certain Sectors

On October 18, 2023 the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a set of new authorizations under the Venezuela sanctions regime, including a temporary suspension of...more

New U.S. Outbound Investment Restrictions on High-Technology Sectors in China

On August 9, 2023, President Biden issued a long-awaited Executive Order establishing the legal authority for the U.S. Department of Treasury (“Treasury Department”) to institute an unprecedented regulatory regime restricting...more

DOJ OFAC BIS Joint Compliance Note and Enhanced Coordination Highlights Increased Enforcement Risk

On July 26, 2023, the U.S. Departments of Justice, Treasury, and Commerce issued a joint compliance note (“JCN”) regarding voluntary self-disclosure (“VSD”) policies that apply to potential violations of U.S. sanctions...more

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