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New Multi-Jurisdictional Sanctions Continue to Target Broad Scope of Activities With Russia

In conjunction with the Group of Seven (G7) leaders meeting in Italy earlier this month, key jurisdictions issued the latest in a series of coordinated economic restrictions on Russia in light of its invasion of Ukraine in...more

Hiding in Plain Sight: New Ukraine and Israel Aid Package Includes Significant Changes to US Sanctions and Export Control Laws

On April 24, 2024, President Biden signed into law H.R. 815, an emergency appropriations package billed as authorizing $95 billion in foreign aid to Ukraine and Israel (the Act). While the Ukraine and Israel aid provisions...more

U.S. Agencies Caution Foreign-Based Persons on Extraterritorial Reach of U.S. Sanctions and Export Control Regulations

On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more

OFSI Encourages Self-Reporting of Sanctions Breaches

Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more

Enhanced Global Russian Sanctions and Export Controls to Counter Circumvention

On May 19, in response to Russia’s ongoing invasion of Ukraine, the United States, in coordination with allies and partners, announced new sanctions restrictions and export controls targeting Russia’s evasion networks,...more

Building Ransomware Resilience - A Proactive Strategy for Businesses and Regulators

The rise of ransomware attacks has prompted the international community to explore a range of approaches to deter these attacks, including the use of sanctions, the further development and instantiation of norms governing...more

OFSI Issues Updated Guidance Relating to Assessments of due Diligence Conducted in Relation to the “Ownership and Control” Test,...

The Office of Financial Sanctions Implementation (OFSI) has updated its ‘enforcement and monetary penalties for breaches of financial sanctions’ guidance, which was last updated in June 2022. ...more

Criminal Vs. Civil Liability Amid Growing Crypto Enforcement

The emergence of digital assets has brought new risks and challenges, including the potential exploitation of the technology to facilitate financial crime. The U.S. Department of Justice has committed to work with its law...more

Sanctions Update: Policymakers Worldwide Rolling Out New Measures to Increase the Economic Costs of Russia’s War Against Ukraine

Western sanctions against Russia have continued to broaden substantially into new areas of trade, especially in the energy sector. Policymakers in Washington DC, Brussels, London and other allied capitals also continue to...more

Top EU Court rules on the EU Blocking Regulation against U.S. sanctions for the first time

Top EU Court Rules on the EU Blocking Regulation Against US Sanctions for the First Time - On December 21, 2021, the Court of Justice of the European Union (CJEU), sitting as a “Grand Chamber” (a formation used, among...more

OFAC Imposes New Sanctions to Thwart Ransomware

On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more

Biden: The Fight Against Foreign and Transnational Corruption Is a National Security Interest

On June 3, 2021, President Biden issued a National Security Memorandum establishing the fight against corruption both at home and abroad as a core United States national security interest and directing the development of a...more

COVID-19: Impacts on US Sanctions Regulation and Policy

The COVID-19 pandemic has had profound economic and political effects over the past several months. Increasingly, those effects have led a number of US policymakers, US allies, and others to question certain US sanctions...more

President Trump Signs Executive Order Blocking the Property of the Venezuelan Government

On August 5, 2019, President Donald Trump signed Executive Order 13884, Executive Order Blocking Property of the Government of Venezuela (EO 13884). EO 13884 is designed to further increase pressure on the Nicolás Maduro...more

Anti-Money Laundering and Sanctions: Trends and Developments Emerging Under the Trump Administration

Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more

OFAC Crystallizes Expectations for Sanctions Compliance

On March 27, 2019, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with US-based Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd....more

US Sanctions PdVSA to Increase Pressure on Maduro Regime

Yesterday, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) pursuant to Executive Order 13850, adding the state-owned Venezuelan oil company to its...more

OFAC Identifies Digital Currency Addresses in Sanctions Designations and Provides FAQs on Digital Currency Compliance

On November 28, the Treasury Department sanctioned two Iran-based individuals for exchanging bitcoin into Iranian rials on behalf of malicious cyber actors involved in the SamSam ransomware scheme. Notably, this action marks...more

Iran Sanctions After the Trump Administration's JCPOA Withdrawal

On Tuesday, May 8, President Trump announced that the United States would end its participation in the Joint Comprehensive Plan of Action (JCPOA), signed by the Permanent Five Members of the Security Council plus Germany...more

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