News & Analysis as of

Office of Foreign Assets Control

US Persons and Financial Institutions: Beware when engaging financially with Venezuela

by Foodman CPAs & Advisors on

On 8/25/17, President Donald Trump signed an Executive Order (EO) restricting and prohibiting certain transactions between US Persons and Venezuela. The transactions that are prohibited by US Persons apply wherever a US...more

Despite Revocation of Sudanese Sanctions, Considerations Remain for Those Dealing With Sudan (IRB No. 568)

by Bryan Cave on

Effective October 12, 2017, the U.S. Government has revoked its sanctions against Sudan that were established in Executive Orders 13067 and 13412 and removed a number of Sudanese entities from the SDN List. The revocation...more

Comprehensive Embargo on Sudan Lifted, Although Some Restrictions Remain

by K&L Gates LLP on

Effective October 12, the Trump administration revoked the U.S. embargo on Sudan in accordance with Executive Order 13761 (Jan. 13, 2017) and Executive Order 13804 (July 11, 2017). As a result of this action, Sudan and the...more

U.S. Lifts Sudan Sanctions

by Fox Rothschild LLP on

On October 12, 2017, the United States lifted its general commercial embargo on Sudan. Because Sudan has played a role in international terrorism, the U.S. has maintained a comprehensive embargo against Sudan since 1997....more

President Trump’s JCPOA Announcement Is More Complicated Than It Looks

by Alston & Bird on

On October 13, 2017, President Trump announced a new national security strategy regarding Iran that may eventually affect current economic sanctions restrictions involving Iran. The President in his comments noted that he...more

Sudan Sanctions Lifted

by Goodwin on

Effective October 12, 2017, U.S. sanctions against Sudan have been lifted. U.S. persons are no longer prohibited from engaging in most transactions involving Sudan and the government of Sudan....more

United States Eases Sudan Sanctions

by White & Case LLP on

After 20 years of comprehensive sanctions against Sudan, the US government has revoked most sanctions with respect to Sudan and the Government of Sudan effective October 12, 2017. As a result of this action, US persons1 are...more

Trump Administration Lifts U.S. Sanctions on Sudan; Important Limitations Remain

Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more

Not out of the woods yet: What the lifting of Sudan sanctions means for businesses and non-profits

by Hogan Lovells on

Yesterday, on October 12, 2017, the U.S. permanently revoked most sanctions against Sudan. This lifting represents the completion of a process that began in January 2017, and was extended in July 2017. ...more

US lifts most sanctions on Sudan—but key controls and heightened concerns remain

by Dentons on

On October 12, 2017, the United States lifted its general commercial embargo on Sudan, removing sanctions that had prohibited US Persons from engaging in or facilitating most transactions involving Sudan or its government....more

Today, President Trump Decertified the Iran Deal and Announced Tougher Sanctions on Iran

What does decertification mean? For the time being, decertification is a solely U.S. issue. Under the Iran nuclear agreement (known as the Joint Comprehensive Plan of Action, or JCPOA), Iran agreed to limits on its nuclear...more

Five on Friday – Five Recent Developments that We’ve Been Watching Closely - October 2017

It’s Friday and time for another overview of developments in the field of business and human rights that we’ve been monitoring. This week’s post includes: a paper from on the proposed draft elements for an international...more

United States Revokes Sanctions on Sudan; Some Restrictions Remain in Place

by Jones Day on

On October 6, 2017, the United States announced that, effective October 12, 2017, it will substantially revoke sanctions on Sudan and the Government of Sudan in recognition of the Government of Sudan's sustained positive...more

US Revokes Sudan Sanctions

On October 6, 2017, President Donald Trump and the U.S. Department of State announced the revocation of economic sanctions on Sudan, following the temporary lifting of sanctions on January 17, 2017. The announcement concluded...more

Sanctions Round Up: Third Quarter 2017

by Shearman & Sterling LLP on

The third quarter was headlined by the imposition of broad new US legislative sanctions against Russia, Iran, and North Korea. The Trump Administration also acted unilaterally to significantly expand sanctions against both...more

United States Lifts Sanctions and Ends 20-Year-Old Embargo Against Sudan

by Reed Smith on

Following a 16-month diplomatic effort, on October 6, 2017, the U.S. government announced that it will terminate the vast majority of economic sanctions against Sudan. The revocation, which will be effective on October 12,...more

The Paper Caper: U.S. Persons Cannot Help Foreign Subsidiaries Or Affiliates With Sanctioned Country Transactions

by Kelley Drye & Warren LLP on

A recent settlement agreement between the Office of Foreign Asset Control (OFAC) and BD White Birch Investment LLC, a U.S.-based paper company, is an important reminder that U.S. companies cannot assist their foreign...more

U.S. embargo on Sudan permanently lifted, but some restrictions remain

by Kelley Drye & Warren LLP on

On October 6, 2017, the State Department announced that the U.S. would permanently lift the embargo on Sudan effective October 12, 2017. The decision comes 10 months after President Obama lifted the embargo on an interim...more

OFAC implements changes to Ukraine-/Russia-related Directives 1 and 2

by Dentons on

On September 29, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended and re-issued Ukraine-/Russia-related sanctions Directives 1 and 2. The amendments were made pursuant to the Countering...more

Implementing CAATSA - OFAC Issues Amended Russian-Related Sectoral Sanctions Under Directives 1 and 2

On September 29, 2017, OFAC modified Directives 1 and 2 of Executive Order 13662 to reduce the permissible maturity for new debt issued by Russian financial and energy entities designated under these directives, as well as...more

Comply With the U.S. Treasury’s OFAC Regulations and Avoid Possible Enforcement Action

by Butler Snow LLP on

For a variety of reasons, the United States government prohibits foreign and domestic individuals, groups, companies and other entities from enjoying the benefits of participating in the U.S. economy. ...more

New Sanctions Against North Korea Issued by the United States

by Shipman & Goodwin LLP on

In light of continuous and escalating tensions between North Korea and the United States, companies should be aware of new sanctions against North Korea issued by the United States. On September 20, 2017, the White House...more

US Amends Russia Sanctions Directives on Debt for Financial and Energy Sectors

by White & Case LLP on

On September 29, 2017, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended Directive 1 and Directive 2 of the Russia Sectoral Sanctions in accordance with Section 223 of the Countering...more

U.S. Sanctions Update: U.S. Expands Sanctions on North Korea (IRB No. 566)

by Bryan Cave on

On September 20, 2017, President Trump issued Executive Order 13810 setting forth measures intended to further isolate North Korea through the imposition of additional sanctions on North Korean persons and on persons doing...more

Implications Arising from the Recent Venezuelan Sanctions

by Morgan Lewis on

Though intended to avoid stifling trade in existing Venezuelan government bonds, the sanctions include restrictions on dealings in certain bonds that could impact bond holders....more

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