Compliance Perspectives: Sanctions, Data and Vetting Third Parties
Polsinelli Podcast - An International Trade Issue That May Impact Your Business
On November 24, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $4,677,552 civil monetary penalty against an anonymous U.S. individual (referred to only as “U.S. Person-1”)...more
On 22 October 2025 the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated two of Russia’s largest energy companies, Rosneft and Lukoil, as well as numerous of their subsidiaries, on the...more
I. Introduction: The Human Consequences of Asset Blocking - Economic sanctions enforced by the U.S. Treasury’s Office of Foreign Assets Control (OFAC) are some of the most powerful tools in U.S. foreign policy. When a...more
On September 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued its “Reminder to File the 2025 Annual Report of Blocked Property.” Entities or persons subject to the reporting...more
Introduction - The Office of Foreign Assets Control (OFAC), part of the U.S. Department of the Treasury, is the agency responsible for enforcing America’s economic sanctions. One of its most powerful tools is the Specially...more
The Department of the Treasury’s Office of Foreign Assets control (OFAC) issued a final rule amending specific reporting and procedural regulations effective November 7, 2024. OFAC published the interim final rule on May 10,...more
On August 2, 2024, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License ("GL") 99A, which authorizes through October 12, 2024, the wind-down of transactions...more
El 5/8/2024, la OFAC enmendó y emitió una Regla Final Interina sobre las Regulaciones de Reportes, Procedimientos y Sanciones (“RPPR”) que establece requisitos estándar de presentación de reportes y mantenimiento de registros...more
On 05/08/2024, OFAC amended and issued an interim final rule on the Reporting, Procedures and Penalties Regulations (RPPR) which sets forth standard reporting and recordkeeping requirements and license application and other...more
On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (IFR), effective August 8, 2024, that updates the Reporting, Procedures, and Penalties Regulations....more
ACI’s highly anticipated Proficiency Series on Economic Sanctions provides true immersion into Economic Sanctions with the objective of becoming proficient in 4 weeks. Advance your career and professional development by...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
For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more
On April 14, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 14059, against two Chinese entities and five individuals based in China and Guatemala for...more
As one of its last acts of 2022, Congress aimed to close loopholes in the Anti-Money Laundering Act of 2020 (AMLA) that left it unclear how and how much whistleblowers would be paid. On Dec. 23, 2022, Congress passed the...more
Switzerland implemented the remaining measures of the EU ninth package of sanctions in its Ordinance on Measures Connected with the Situation in Ukraine (the "Ordinance"switz), with effect from 25 January at 18:00 CET. These...more
UPDATE – December 2022 was another busy month for Entity List additions by BIS. Effective Dec. 21, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) further tightened controls on the Wagner...more
Recently, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has taken additional actions against Russia in response to its continued invasion of Ukraine. Specifically, OFAC: ..Issued guidance...more
Over the past few weeks, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury ramped up sanctions pressure against Russia with the announcement of a new ban on certain services in seaborne Russian...more
On August 16, 2022, the United States Court of Appeals for the D.C. Circuit issued its ruling in Estate of Jeremy Isadore Levine, et al. v. Wells Fargo Bank, N.A., No. 21-7036, –F.4th– (D.C. Circuit August 16, 2022), a case...more
Over the past few weeks, the US Department of Treasury Office of Foreign Assets Control (OFAC) took various actions in response to Russia’s continued invasion in Ukraine: ..updated the Specially Designated Nationals and...more
In their June 2022 report “The cost of complacency: illicit finance and the war in Ukraine”, the House of Commons Foreign Affairs Committee (the “FAC”) condemned the UK Government’s historic lack of commitment to tackling...more
Key Takeaways - ..The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is prohibiting the provision of accounting, trust and corporate formation, and management services to any person in the...more
U.S. contractors with global operations are likely aware of the significant restrictions imposed by the federal government in response to the Russian invasion of Ukraine, in the form of new sanctions, allied trade embargoes,...more
Following a meeting of G7 leaders on May 8, 2022, the United States enacted additional sanctions and export control measures in response to the ongoing conflict in Ukraine. Among the changes: a prohibition on U.S. persons...more