News & Analysis as of

Office of Foreign Assets Control (OFAC) Biden Administration U.S. Treasury

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

Troutman Pepper Locke

Financial Transactions Related to Russian Energy Now Prohibited: Expiration of OFAC ‎General License 8L

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On March 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) allowed General License (GL) 8L under the Russian Harmful Foreign Activities Sanctions Regulations to expire. As a result, broad OFAC...more

Holland & Knight LLP

Trump Administration Rescinds Certain Actions by the Previous Administration to Ease Cuba Sanctions

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Within hours after taking office on Jan. 20, 2025, U.S. President Donald Trump signed an omnibus executive order revoking 78 executive actions by the previous administration, dating back to 2021. Among them, President Trump...more

Akin Gump Strauss Hauer & Feld LLP

Designation Of Ansar Allah as a Foreign Terrorist Organization (Trump EO Tracker)

Summary This Order re-designates Ansar Allah (also known as the Houthis) a Foreign Terrorist Organization (“FTO”), to be effective within 45 days. The first Trump Administration had previously designated the Houthis as an FTO...more

Skadden, Arps, Slate, Meagher & Flom LLP

Russia’s Energy, Financial and Defense Sectors Are the Focus of the Last Round of Sanctions Under Biden

In the days before former President Joe Biden left office, the U.S. announced two new rounds of sanctions against Russia, including expansive new sanctions against Russia’s energy sector. According to its press release, the...more

Holland & Knight LLP

U.S. Announces Steps to Ease Cuba Sanctions

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Besides certain expansions on remittances in 2022, the White House, on Jan. 14, 2025, issued a statement announcing President Joe Biden's plans to relax sanctions on Cuba through a series of broad measures aimed at improving...more

Troutman Pepper Locke

A Minefield in Russia’s Energy Sector: Biden’s Final Sanctions Act May be Game-Changing

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Days before President Biden leaves the White House, the U.S. government has delivered a major blow against Russia. On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced...more

Bracewell LLP

Biden Administration Issues Sweeping Salvo of Sanctions Against the Russian Energy Sector

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On January 10, 2025, in a final action to, among other things, deter Russian aggression on the international stage, the US Department of the Treasury enacted sweeping new sanctions on the Russian energy sector. Specifically,...more

Eversheds Sutherland (US) LLP

Biden Administration imposes sweeping sanctions against the Russian Energy Sector days ahead of the Trump Transition

On January 10, 2025, the Biden Administration issued a broad sanctions package targeting the Russian energy sector, 10 days in advance of the transition to the incoming Trump Administration. The new sanctions also added two...more

Ropes & Gray LLP

Russia/Ukraine Crisis: U.S. Targets Russia’s Energy Industry

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On January 10, 2025, the United States announced (another) major sanctions package targeting Russia, potentially representing the Biden administration’s last and best effort to strengthen Ukraine’s negotiating position in...more

Holland & Knight LLP

OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

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Nearly six months after President Joe Biden signed an executive order (EO) authorizing secondary sanctions against Foreign Financial Institutions (FFIs) conducting or facilitating significant transactions with certain...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - June 2024

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On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an Interim Final Rule (IFR), effective August 8, 2024, that updates the Reporting, Procedures, and Penalties Regulations....more

Pillsbury - Global Trade & Sanctions Law

Treasury Amends the Cuban Assets Control Regulations to Support Cuban Citizens and Independent Private Sector Entrepreneurs

On May 28, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR) to better implement the Biden-Harris Administration’s policy aimed at...more

Brownstein Hyatt Farber Schreck

Venezuela Energy Sanctions Reimposed Barring Democratic Reforms

On April 17, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) released General License (GL) 44A, requiring the wind down of business transactions with Venezuela’s state-owned energy company Petróleos...more

BakerHostetler

Key Sanctions Developments During the First Quarter of 2024

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During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more

Paul Hastings LLP

New Sanctions on Russia Mark Two-Year Anniversary of Ukraine Invasion

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On February 23, 2024, the Biden Administration announced new sanctions targeting a number of different sectors of the Russian economy, Russian government officials and financial institutions, entities suspected of sanctions...more

A&O Shearman

U.S. Government announces new West Bank-related sanctions and designations

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On February 1, 2024, President Biden issued an Executive Order imposing certain sanctions on persons determined to be undermining peace, security, and stability in the West Bank. In response to current hostilities and...more

The Volkov Law Group

New Executive Order Expands Treasury’s Authority to Impose ‘Secondary Sanctions’ on Foreign Financial Institutions Involved in...

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On December 22, 2023, President Joseph R. Biden, Jr. issued an executive order—”Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities”—that subjects certain foreign financial institutions that...more

Husch Blackwell LLP

Biden Administration Issues Executive Order to Restrict U.S. Investment in Chinese Technology Sectors

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Last week, President Biden issued an Executive Order outlining the long-anticipated proposed restrictions on outbound U.S. investments in entities located in China or otherwise subject to China’s jurisdiction. The Executive...more

Goodwin

Charlie Brown Finally Kicks the Football: US Outbound Investment Program Will Target China’s Semiconductor, Quantum Computing, and...

Goodwin on

After months of speculation, the US government took steps to regulate outbound investment in specific foreign industries of concern. President Biden on August 9, 2023, issued Executive Order 14105 directing the Department of...more

Dorsey & Whitney LLP

Executive Order 14105 on Outbound Investment in China and Proposed Rule

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On August 9, President Biden issued Executive Order 14105 (“EO 14105”) on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern. EO 14105 significantly reshapes...more

Ballard Spahr LLP

Andrea Gacki, Former Director of OFAC, Appointed Director of FinCEN

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Yesterday, the Department of the Treasury announced that Andrea Gacki, who had been serving as the Director of the Office of Foreign Assets Control (OFAC), has been appointed as the Director of the Financial Crimes...more

Williams Mullen

OFAC Prohibits Providing Accounting, Trust/Corporate Formation and Management Consulting Services for Russian Parties

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​​​​​​​On May 8, 2022 the Office of Foreign Assets Control (OFAC) announced that the performance of accounting, trust and corporate formation and management consulting services for persons located in the Russian Federation...more

Wiley Rein LLP

Biden Administration Toughens Sanctions, Export Controls in Response to Continued Harmful Activities of the Russian Government

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On September 15, 2022, the Biden Administration announced a new package of sanctions and export controls to hold the Russian government accountable for its war against Ukraine. ...more

The Volkov Law Group

United States Pushes More Sanctions Against Russia and Prohibits Russian Gold Imports

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The Department of Treasury issued additional sanctions against Russia, targeting almost 100 entities and individuals, and prohibited import of Russian gold.  The United States’ latest action reflected commitments recently...more

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