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International Emergency Economic Powers Act (IEEPA) Office of Foreign Assets Control (OFAC) Today's Popular Updates

Bracewell LLP

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

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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

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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

Husch Blackwell LLP

Week Seven in Trade – First 100 Days of the New Administration

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The tariffs imposed by President Trump on Canada and Mexico under the International Emergency Economic Powers Act of 1977 (IEEPA) went into effect on March 4, 2025. Our initial posting on this development can be found here....more

DLA Piper

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

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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

Hogan Lovells

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

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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

BCLP

Fifth Circuit Rules OFAC Cannot Sanction Tornado Cash: Loper Bright Hamstrings OFAC’s Campaign Against Crypto Laundering

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Shortly before Thanksgiving, a panel of the United States Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) did not have the authority to sanction Tornado Cash, which offers a...more

White & Case LLP

Sanctions move up the agenda for lenders and borrowers

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Compliance with sanctions regimes has been a priority for debt markets. Amid rising geopolitical tensions, the stakes for lenders and borrowers are higher than ever - Intensifying geopolitical tensions and the US...more

Benesch

New Statute of Limitations Impacts M&A and International Trade Compliance

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New developments in international trade laws will have tangible and far-reaching impacts on transactions as well as day-to-day business operations.  President Biden’s signing of HR 815 means that once time-barred historic...more

Hogan Lovells

Statute of limitations extended for violations of U.S. sanctions

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Congress has doubled the statute of limitations for violations of most U.S. sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control.  Companies should be aware of the...more

Fenwick & West LLP

Sanctions Violations: New 10-Year Statute of Limitations

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On April 24, 2024, President Biden signed into law an emergency supplemental appropriations law, H.R. 815 (Public Law 118-50), that provides substantial military aid to Ukraine, Israel, and Taiwan and could force the sale of...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

The Volkov Law Group

DOJ Reaches Groundbreaking Criminal Settlement with Cryptocurrency Exchange Binance and CEO Changpeng Zhao (Part I of III)

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On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as...more

Ballard Spahr LLP

Steel Company President with Ties to Russian Oligarch Pleads Guilty to Money Laundering Conspiracy Involving Alleged Sanctions...

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Earlier this month, John Can Unsalan, the president of a steel-making company with ties to Russian oligarchs, pled guilty to one count of conspiracy to commit money laundering, based on financial transactions committed with...more

Lowenstein Sandler LLP

Trade Matters -Lowenstein Sandler's Global Trade & National Security Newsletter - June 2023

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Crypto Asset Company Settles Sanctions Violations for $7.5 million- On May 1, the U.S. Department of Foreign Assets Control (OFAC) announced a $7.5 million settlement with crypto asset company Poloniex LLC for 65,942 apparent...more

K2 Integrity

The North Korean Crypto Threat

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Executive Summary - The North Korean threat to the crypto ecosystem is the highest form of immediate risk to the crypto-economy driven by a regime that seeks to profit from its misuse to reinforce its regime and fuel all its...more

Troutman Pepper Locke

Sanctions Round-up and Possible New Russia Sanctions Triggered by Hostilities Against Ukraine

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The United States, primarily through Presidential action under the statutory authority of the International Emergency Economic Powers Act (“IEEPA”), has empowered the U.S. Department of the Treasury and its Office of Foreign...more

Orrick, Herrington & Sutcliffe LLP

Treasury Actions to Counter Ransomware

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several actions focused on disrupting criminal digital finance infrastructure, including virtual currency...more

Morgan Lewis

OFAC Issues Updated Advisory on Sanctions Risks for Facilitating Ransomware Payments

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The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” This advisory continues prior advisory...more

Foley & Lardner LLP

White House Issues Open Letter to Private Businesses Regarding the Threat of Ransomware

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On June 2, 2021, Anne Neuberger, Deputy Assistant to the President and Deputy National Security Advisor for Cyber and Emerging Technology, published a rare open letter to the corporate executives and business leaders of...more

King & Spalding

Ransomware on the Rise in Critical Infrastructure Sector

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Recent ransomware attacks against U.S. critical infrastructure, which includes the energy sector’s production of oil and natural gas, and other sources of electricity and power, have shed a spotlight on the importance of...more

Williams Mullen

Understanding the OFAC Sanctions Laws: Requirements for U.S. Companies

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It seems almost every day there are reports of new developments under the U.S. sanctions laws. Yet many U.S. companies do not understand the significance of these laws....more

Snell & Wilmer

OFAC Issues Advisory on Ransomware Payments

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On October 1, 2020, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory regarding the potential sanctions risk for entities that facilitate ransomware payments. OFAC defined “ransomware” as: A form...more

Foley Hoag LLP

First A Ransomware Attack, Now Sanctions? New OFAC Advisory Warns of Sanctions Risks for Facilitating Ransomware Payments

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On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an advisory regarding potential sanctions risks related to facilitating ransomware payments... OFAC is the federal...more

King & Spalding

Ransomware: To Pay or Not to Pay?

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Ransomware has emerged as one of the most virulent cybersecurity risks, affecting public and private sector alike. In recent years, ransomware attacks have become more focused, sophisticated, costly, and numerous. Threat...more

Bilzin Sumberg

OFAC Issues Regulatory Advisory Warning Against Facilitating Ransomware Payments

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On October 1, 2020, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an “Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” The Advisory, which does not carry the...more

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