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Export Controls Economic Sanctions Office of Foreign Assets Control (OFAC)

The Volkov Law Group

Episode 376 -- DOJ's Unicat Settlement and the Future Look of Trade Enforcement Actions

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What happens when a company inherits a sanctions violation through acquisition, and acts fast to fix it? Can a robust post-acquisition response really save a parent company from prosecution? In this episode, Michael...more

Wilson Sonsini Goodrich & Rosati

From Embargo to Engagement: U.S. Reopens Doors to Syria

After the fall of the former regime of Bashar al-Assad in Syria, the Presidential Administration has taken steps to formally dismantle the U.S.’s two-decade-long comprehensive trade restrictions on Syria. These steps began...more

Troutman Pepper Locke

With Additional Syria Sanctions Relief, Risks Remain

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On June 30, 2025, President Trump issued an executive order (EO) that, effective July 1, revokes the U.S. sanctions program on Syria, and calls for the removal of the Syrian Sanctions Regulations from the Code of Federal...more

Kelley Drye & Warren LLP

White House Terminates Most Syria Sanctions

On June 30, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented the President’s Executive Order ​“Providing for the Revocation of Syria Sanctions,” (Syria EO) which removes U.S. sanctions on...more

A&O Shearman

DOJ Issues First-Ever Declination For Sanctions Violations Since Creation Of The M&A Safe Harbor Policy

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On June 16, 2024, the U.S. Department of Justice’s (“DOJ”) National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas (“SDTX”) announced the first-ever declination to prosecute a firm...more

McDermott Will & Emery

From risk to relief: PE firm avoids prosecution with swift disclosure

In June 2025, the US Department of Justice (DOJ) announced that it declined to prosecute a private equity firm and its affiliates following the firm’s voluntary self-disclosure of criminal violations of US sanctions and...more

The Volkov Law Group

Lessons Learned from the Unicat Settlement (Part III of III)

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The Unicat settlement provides some important insights into the Trump Administration’s direction on trade enforcement. It underscores the importance of voluntary disclosure, cooperation and remediation, the tri-part...more

Proskauer Rose LLP

DOJ Declination of Private Equity Firm Underscores Need for Robust M&A Due Diligence

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On June 16, 2025, the U.S. Department of Justice (“DOJ”), including its National Security Division (“NSD”) and the U.S. Attorney’s Office for the Southern District of Texas, announced that they would not prosecute White Deer...more

The Volkov Law Group

DOJ’s Coordinated Resolution with Unicat Resolves OFAC, BIS and CBP Violations (Part II of III)

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DOJ’s Unicat resolution is a perfect example of the new trade enforcement reality under the Trump Administration.  DOJ spearheaded a global resolution of sanctions, customs and export controls violations, while declining to...more

The Volkov Law Group

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A...

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In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies...more

White & Case LLP

DOJ Declines to Prosecute Private Equity Firm after Post-Acquisition Voluntary Self-Disclosure of Sanctions and Export Control...

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In its first application of the policy on voluntary self-disclosures (“VSDs”) in connection with mergers and acquisitions (“M&A”), on June 16, 2025, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”)...more

Akin Gump Strauss Hauer & Feld LLP

Acquirors Beware: PE Firm Escapes DOJ Prosecution, but Acquired Entity Hit With $2 million+ in Penalties

In March 2024, NSD issued an updated Enforcement Policy for Business Organizations (NSD Enforcement Policy) that includes the M&A Policy.  Under the M&A Policy, where an acquiring company makes a qualifying voluntary...more

Mayer Brown

UK Weekly Sanctions Update - Week of June 16, 2025

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In this weekly update, we summarise the most notable updates in the UK sanctions world. Russia Sanctions UK government adds 10 new entries and specifies 20 ships under the Russia regime: On June 17, 2025, the UK government...more

Vinson & Elkins LLP

Commercial Considerations Related to the Shift in Syrian Sanctions Policy

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On May 23, 2025, General License 25 (“GL 25” or the “General License”) was issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), suspending a wide array of sanctions against Syria....more

Benesch

Pragmatic Regulatory Compliance for Global Risk

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Geopolitical risks to supply chains are top of mind across C-suites, but few say what it means. The term “geopolitical risk” has largely become a code word for import, export, and economic sanctions compliance. ...more

Morrison & Foerster LLP

Trump Administration Issues Broad Sanctions Relief for Syria, Effectively Lifting 14 Years of Comprehensive Economic Sanctions –...

On May 23, 2025, 10 days after President Trump announced his directive to lift U.S. sanctions on Syria during his visit to Saudia Arabia last month, the U.S. Department of the Treasury’s Office of Foreign Assets Control...more

Hogan Lovells

OFAC lifts certain sanctions on Syria, broad export controls remain in place

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General License (GL) 25 authorizes transactions previously prohibited by various regulations. Specifically, Section (a) broadly authorizes activities previously prohibited under the Office of Foreign Asset Control (OFAC)’s...more

Skadden, Arps, Slate, Meagher & Flom LLP

A New Day for Syria: Trump Administration Relaxes Sanctions

On May 23, 2025, the Trump administration issued a general license (GL) significantly relaxing the patchwork of restrictions on Syria, long a jurisdiction subject to comprehensive sanctions. This regulatory action followed a...more

Cooley LLP

US, UK and EU Begin Easing Sanctions on Syria Amid Political Transition

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Following an announcement by President Donald Trump on May 13, 2025, that he would order the cessation of US sanctions against Syria, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General...more

ArentFox Schiff

So Long Syria Sanctions? Not So Fast!

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On May 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25, “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain...more

Foley Hoag LLP

U.S. and EU Take Steps Towards Easing Sanctions on Syria

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On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 25 (“GL 25”) authorizing certain transactions involving Syria and a specified list of blocked...more

Bass, Berry & Sims PLC

U.S. Government Eases Some Restrictions on Syria

On May 23, 2025, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced several actions to provide sanctions relief to Syria. OFAC is the primary government agency responsible for administering U.S....more

WilmerHale

The United States and European Union Offer Sanctions Relief to Post-Assad Syria

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Following the fall of Syria’s Assad regime, the United States and key allies have recently announced sanctions relief with the stated goal of stabilizing Syria under its newly installed leaders. ...more

Miles & Stockbridge P.C.

U.S. Provides Significant Sanctions Relief for Syria

Less than two weeks after President Donald Trump announced that his administration would lift U.S. sanctions on Syria, the U.S. Departments of the Treasury and State took significant first steps to provide the anticipated...more

BakerHostetler

Syria Sanctions Eased: What is the Impact on Your Business?

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On May 23, 2025, the United States formally eased its economic sanctions on Syria. This action authorizes a significant number of transactions that previously would have violated U.S. sanctions. ...more

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