News & Analysis as of

International Emergency Economic Powers Act (IEEPA) Office of Foreign Assets Control (OFAC) National Security

Miles & Stockbridge P.C.

Lifting Sanctions On Syria: A Preview of the Process

President Donald Trump announced Tuesday during his trip to the Middle East that his administration would lift U.S. sanctions on Syria. Since the shock collapse of Bashar al-Assad’s regime in Syria late last year, the...more

WilmerHale

Limits of IEEPA’s Designation Authority

WilmerHale on

Over the first 100 days and beyond, the Trump Administration has deployed national security authorities in novel ways. Perhaps most notably, President Trump has asserted authority under the International Emergency Economic...more

Bracewell LLP

Trump Administration Efforts to Eliminate Cartels Pose Heightened Risk for Financial Institutions

Bracewell LLP on

As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

K2 Integrity on

On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more

Foley & Lardner LLP

What Every Multinational Company (Doing Business in Mexico) Should Know About … Mitigating Risks From ATA Scrutiny in a New...

Foley & Lardner LLP on

Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more

K2 Integrity

Escalation Against Cartels: U.S. Designates International Cartels as Foreign Terrorist Organizations and Specially Designated...

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On 20 February 2025, the United States (U.S.) Department of State designated eight international cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The designation of...more

Latham & Watkins LLP

Trump Administration Targets Cartels With First Wave of Terrorism Designations

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The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....more

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

DLA Piper on

Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

Dorsey & Whitney LLP

Attorney General Bondi Reorients National Security Enforcement Resources to Focus on Illegal Immigration and Drug Trafficking

Dorsey & Whitney LLP on

Upon being sworn in on February 5, 2025, Attorney General Pamela Bondi immediately issued memoranda reorienting national security enforcement resources of the U.S. Department of Justice (“DOJ”) to focus on addressing illegal...more

Hogan Lovells

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

Hogan Lovells on

The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more

Holland & Knight LLP

Executive Order: Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global...

Holland & Knight LLP on

Date Issued: Jan. 20, 2025 This executive order initiates the process of designating certain international cartels as Foreign Terrorist Organizations (FTOs) to address the rise in violence and terror across the western...more

Troutman Pepper Locke

Tornado Cash Whiplash – What’s Next for Sanctions?

Troutman Pepper Locke on

We find ourselves in the midst of a raucous debate among sanctions practitioners about the impact of the Fifth Circuit’s recent decision upholding a challenge against the sanctions the Office of Foreign Assets Control (OFAC)...more

Venable LLP

Trump Administration Prepares to Levy Novel Tariffs

Venable LLP on

As anticipated from campaign promises, on Monday, January 20, President Donald Trump issued an executive order (EO) commencing the process to levy a host of new trade tariffs as part of his "America First Trade Policy." New...more

Akin Gump Strauss Hauer & Feld LLP

Designating Cartels And Other Organizations As Foreign Terrorist Organizations And Specially Designated Global Terrorists

This Order declares a national emergency under the International Emergency Economic Powers Act (IEEPA) to designate certain international cartels and other organizations as Foreign Terrorist Organizations or Specially...more

Morrison & Foerster LLP

OFAC Extends Recordkeeping Requirements from Five to 10 Years; Issues Paperwork Reduction Act Request for Comments

On September 11, 2024, OFAC announced its Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years. The Interim Final Rule (IFR) was published in the Federal Register on September 13, 2024. Public...more

Seward & Kissel LLP

Compliance Flash: OFAC Announces New Reporting Requirement for Financial Institutions Under the REPO for Ukrainians Act

Seward & Kissel LLP on

The supplemental appropriations legislation signed into law on April 24, 2024 enacted numerous high-profile provisions addressing aspects of U.S. foreign policy and national security, including provisions that broaden and...more

Paul Hastings LLP

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

Paul Hastings LLP on

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

Holland & Knight LLP

Commerce Department: Final Determination of Russia-Backed Cybersecurity, Antivirus Software

Holland & Knight LLP on

The U.S. Department of Commerce's Office of Information and Communications Technology and Services (OICTS) within the Bureau of Industry and Security (BIS) issued a Final Determination on June 20, 2024, pursuant to Executive...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - June 2024 - New Legislation Extends Statute of Limitations for Sanctions Violations

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

The Volkov Law Group

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

The Volkov Law Group on

On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls...more

Blank Rome LLP

President Biden Signs into Law Ten-Year Statute of Limitations for Sanctions Violations and Other National Security Measures

Blank Rome LLP on

President Biden last month signed into law H.R. 815 (“National Security Supplemental” or “NSS”). The NSS—a package of national security and foreign aid appropriations, including for efforts in Israel, Ukraine, and the...more

Alston & Bird

National Security Act Ushers In Sweeping Changes to Sanctions Regulations

Alston & Bird on

On April 24, 2024, President Biden signed H.R. 815, otherwise known as the National Security Act of 2024. The bill provides emergency appropriations for Ukraine, Israel, Taiwan, humanitarian purposes in Gaza, and various...more

Akin Gump Strauss Hauer & Feld LLP

Congress Extends Statute of Limitations for Sanctions and Certain Other National Security Programs from 5 to 10 Years and...

While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more

Mayer Brown

US Congress Extends Statute of Limitations for Sanctions and Export Controls

Mayer Brown on

On April 24, 2024, President Biden signed into law H.R. 815, the National Security Supplemental (the “Act”). While much of the focus centered on the foreign aid package for Israel, Ukraine, and the Indo-Pacific, the bill...more

Morrison & Foerster LLP

War Aid and Sanctions: National Security Act Includes Significant New Sanctions Authorities

On April 24, 2024, President Biden signed into law a long-debated $98 billion foreign aid and national security legislative package (the “Act”) providing funds for Israel, Taiwan, and Ukraine, and authorizing new sanctions...more

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