The New Cold War: Risk, Sanctions, Compliance Episode 22: "Focus on Iran: Protests, Sanctions and Oil"
EMBARGOED! Episode 43: Russia and Iran and China, Oh My!
Washington Post Journalist Jason Rezaian on His Iranian Imprisonment
Nota Bene Episode 64: U.S. Check In: Prescription Drugs, USMCA, Privacy, Impeachment and Iran with Elizabeth Frazee and Jonathan Meyer
As the third month of the second Trump administration comes to a close, the lack of any public enforcement action by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctions watchers...more
With unprecedented change and intensifying enforcement, now is the time to ensure your team is prepared for what’s ahead. Ensure that you don’t miss out on critical U.S. and international economic sanctions updates and the...more
This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more
In another step to deprive a sanctioned country of revenues from petroleum sales, the U.S. government recently sanctioned more than 30 entities and vessels located around the world for their role in brokering the sale and...more
In the latest effort to implement its “maximum pressure” campaign targeted at putting a total stop to Iranian oil exports, the Trump administration has imposed another round of sanctions targeting Iran’s oil distribution...more
As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...more
We previously covered President Trump’s IEEPA tariffs and the various retaliatory tariff and nontariff countermeasures announced by each country in separate posts. Currently, the Mexico and Canada tariffs have been paused...more
Following President Trump’s announcement of his administration’s intention to ratchet up sanctions against Iran, OFAC announced Thursday that it is designating a number of Chinese, Indian, and UAE entities as Specially...more
President Trump issued a new Executive Order renewing a commitment to imposing “maximum pressure” on the Iranian government to “end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist...more
Imposes maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist groups. Relevant Secretaries are required to impose and enforce sanctions,...more
Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped...more
Throughout 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control ("OFAC") published 12 enforcement actions regarding alleged sanctions violations by foreign and domestic persons and entities....more
C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more
Despite a relatively slow year in OFAC sanctions enforcement, OFAC closed 2024 with a string of settlements in five cases, including its second in 2024 against an individual defendant. While OFAC had a slow year, DOJ...more
As we wrote previously, the U.S. Department of the Treasury has issued a final rule that takes effect on December 26 that will dramatically raise the Committee on Foreign Investment in the United States (CFIUS) penalties from...more
On Friday, December 27, 2024, the Justice Department issued a final rule to address “urgent national security risks posed by access to U.S. sensitive personal and government-related data from countries of concern and covered...more
In one of the more notable enforcement actions of 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently imposed a $1,104,408 civil penalty on a U.S. person for 75 separate violations...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent...more
On October 31, 2024, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued scenario-based guidance specific to the maritime shipping industry....more
Foreign companies with U.S. operations are struggling to navigate the landscape of sanctions compliance. OFAC has expressed its concern that foreign companies need to deploy U.S. based expertise and resources to ensure...more
Iran and Syria Sanctions and Embargos On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued updated guidance to remind maritime support service providers that the...more
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
Throughout 2023 and early 2024, we continue to witness deepening geopolitical and economic divides globally. The U.S. and its allies (most significantly the EU and the G7), spurred on by Russia’s war in Ukraine, continue to...more
OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws. If you need to find an example of this long reach, look no...more
February saw a continuing focus on Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the State Department, sanctioned over 500 individuals and entities – the “largest number...more