News & Analysis as of

Office of Foreign Assets Control (OFAC)

Oberheiden P.C.

10 Important Facts About FinCEN’s Whistleblower Program

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The Financial Crimes Enforcement Network (FinCEN) is one of a handful of federal authorities that have adopted whistleblower programs focused on facilitating enforcement in hard-to-target areas. While FinCEN focuses its...more

Husch Blackwell LLP

Week Sixteen in Trade

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In its FAQs, U.S. Custom and Border Protection (CBP) clarified the exemption from reciprocal tariffs for goods subject to steel/aluminum Section 232 duties under HTSUS 9903.01.33. CBP clarified that the exemption only applies...more

DLA Piper

US Treasury Takes on Cartels Part Deux: Combating Cartel-Connected Oil Smuggling Schemes

DLA Piper on

The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), in coordination with the Office of Foreign Assets Control (OFAC), the US Drug Enforcement Administration (DEA), the Federal Bureau of...more

Troutman Pepper Locke

Crude Crimes: Treasury Warns on Oil Smuggling and Money Laundering

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The Treasury Department has taken initial steps to implement the Trump administration’s “total elimination” policy directed at certain drug trafficking cartels. Most recently, on May 1, Treasury’s Financial Crimes Enforcement...more

Husch Blackwell LLP

Week Fifteen in Trade

Husch Blackwell LLP on

On May 1st U.S. Customs and Border Protection (“Customs”) issued additional guidance on import duties on certain automobiles through Cargo Systems Messaging Service # 64916414 (the “CSMS”). The CSMS stated the following:...more

Carlton Fields

Recent SEC AML Enforcement Actions and Likely Continued AML Emphasis Under New Administration

Carlton Fields on

Registered investment advisers have until January 1, 2026, to comply with the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). However, the SEC has recently charged two investment advisers with...more

K2 Integrity

[Webinar] Mexico’s Evolving AML/CFT Environment: FATF Review and FTO Designations - May 14th, 12:30 pm ET

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U.S. and Mexican companies and financial institutions are seeking to navigate AML/CFT, sanctions, export control, and tariff and supply chain concerns as their governments’ make rapid changes around trade and tariffs and ramp...more

Mayer Brown

Russia/Ukraine Sanctions Update - Month of April 2025

Mayer Brown on

I. U.S. SANCTIONS  - White House Reportedly Considering Lifting Sanctions on Russian Energy Assets: On April 23, Politico reported that the White House is debating lifting sanctions on Russia’s Nord Stream 2 natural gas...more

Miles & Stockbridge P.C.

Left Out of ‘Liberation Day’: Demystifying Continuing Import Sanctions and Tariffs on Russia

President Donald Trump issued an executive order (EO) earlier this month announcing sweeping “reciprocal” tariffs on imports from countries across the world. One country missing from the EO’s increased tariffs was Russia,...more

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2024 Lessons Learned and 2025 Expectations

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

American Conference Institute (ACI)

[Event] Trade & Sanctions Compliance for the Oil and Gas Industry - May 21st - 22nd, Houston, TX

Between tariffs, tightening export controls, evolving sanctions, and ramped up enforcement, the cost and complexity of compliance is rising for oil and gas supply chains. ACI’s Trade & Sanctions Compliance for the Oil and...more

The Volkov Law Group

Practical Issues and the New DSP (Part II of III)

The Volkov Law Group on

Like any new regulatory and enforcement scheme, companies face a number of new risks that require understanding.  The DSP framework is new, comprehensive and raises significant risks and requires careful design and...more

WilmerHale

Implications of EO 14157 and Recent “Foreign Terrorist Organization” and “Specially Designated Global Terrorist” Designations

WilmerHale on

On January 20, 2025, President Donald J. Trump signed Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists” (EO 14157)....more

Katten Muchin Rosenman LLP

OFAC Issues Updated Guidance to Shipping and Maritime Sector Regarding Evasion of Iranian Oil Sanctions

On April 16, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued an update to its Sept. 2019 advisory, addressed to the global shipping and maritime sector, regarding sanctions evasion...more

Husch Blackwell LLP

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

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This blog post summarizes trade regulatory developments which occurred during the week of April 12-18, 2025. It is current up to 12:00 pm ET on Friday, April 18, 2025. Any developments occurring after that time will be...more

Foley & Lardner LLP

The Non-Compliant Cat in the Hat

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So, just before Easter, in 1957, a little book you may have heard of, called The Cat in the Hat, made its first appearance. Theodore Geisel — writing under the name “Dr. Suess” — later said that of all his children’s books,...more

BakerHostetler

DOJ Implements Bulk Personal Data Transfer Restrictions

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The Data Security Program (DSP) recently implemented by the U.S. Department of Justice (DOJ) will have far-reaching implications for many businesses that transfer the personal data of U.S. citizens outside the United States....more

Husch Blackwell LLP

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

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On April 8, 2025, President Trump issued an Executive Order raising the reciprocal tariff rate on Chinese imports from 34% to 84%. This move followed his earlier warning that the U.S. would impose a 50% increase unless China...more

Venable LLP

A Legal Whirlwind Settles: Treasury Lifts Sanctions on Tornado Cash

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On March 21, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) officially lifted sanctions on Tornado Cash, the decentralized cryptocurrency mixer it had blacklisted in August 2022....more

Bracewell LLP

Post Liberation Day --"Secondary Tariffs" Raise Costs Even Higher for International Actors

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President Trump has used tariffs as a significant point of geopolitical leverage since the beginning of his second term. Indeed, his administration dubbed April 2, 2025 “Liberation Day” in honor of a sweeping set of tariffs...more

K2 Integrity

The Expanding U.S. Economic Statecraft: The Introduction Of “Secondary Tariffs”

K2 Integrity on

On 24 March 2025, President Trump issued Executive Order 14245 authorizing Secretary of State Marco Rubio to impose a 25 percent tariff on all goods imported into the United States from any country that directly or indirectly...more

Miller Canfield

DOJ Rule Restricting Sensitive Data Transfers Takes Effect

Miller Canfield on

Today, April 8, 2025, the U.S. Department of Justice’s Final Rule restricting transfers of bulk sensitive personal data and U.S. government-related data becomes effective, implementing former President Biden’s Executive Order...more

Troutman Pepper Locke

Navigating 2025: Trends in OFAC and DOJ Enforcement for Digital Assets — The Crypto Exchange Podcast

Troutman Pepper Locke on

In this episode of Crypto Exchange, host Ethan Ostroff is joined by his colleagues Pete Jeydel and Peter Leary to discuss trends and lessons learned from recent civil enforcement actions by the Treasury Department's Office of...more

BakerHostetler

Weekly Blockchain Blog - April 2025

BakerHostetler on

U.S. Financial Services Firms Announce Digital Asset Initiatives - A major U.S. financial services company and operator of global financial exchanges and clearinghouses recently announced an agreement with the issuer of the...more

Paul Hastings LLP

Venezuela Sanctions: Wind-Down of General License 41 and Introduction of ‘Secondary Tariffs’

Paul Hastings LLP on

The dynamic pace of early policymaking by the new U.S. administration has continued into the spring of 2025, including in the context of sanctions on Venezuela. While Venezuela is not, and has not been, subject to...more

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