News & Analysis as of

Office of Foreign Assets Control (OFAC) Department of Justice (DOJ) U.S. Treasury

BakerHostetler

Weekly Blockchain Blog - April 2025

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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

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

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

Jones Day

Mitigating Risk From the Designation of Cartels as FTOs and SDGTs

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The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more

White & Case LLP

United States Designates Eight Cartels and Transnational Criminal Organizations

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Effective February 20, 2025, the United States Designated Eight Cartels and Transnational Criminal Organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs)....more

DLA Piper

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

DLA Piper on

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

Seward & Kissel LLP

President Trump Seeks “Maximum Pressure” on Iran Through Expansion of Sanctions Targeting Iran’s Oil Exports

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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

Mayer Brown

Russia/Ukraine Sanctions Update - Month of January 2025

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I.  US SANCTIONS - U.S. Department of the Treasury Takes Action Against Russian Efforts to Evade U.S. Sanctions: On January 15, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated...more

Baker Botts L.L.P.

Compliance, Enforcement, and Litigation Risk Considerations from President Trump’s Executive Order on Designating New Foreign...

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On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” The order directs the...more

Guidepost Solutions LLC

Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more

Akin Gump Strauss Hauer & Feld LLP

National Security Presidential Memorandum/NSPM-2 (Trump EO Tracker)

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

Paul Hastings LLP

Implications for Mexican Banks and Financial Institutions of President Trump’s Designation of Drug Cartels as Foreign Terrorist...

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On his first day in office, President Donald Trump signed an executive order that initiates the process of designating certain drug cartels as foreign terrorist organizations. The executive order is primarily focused on...more

Ballard Spahr LLP

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

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In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado...more

Whiteford

Client Alert: DOJ and OFAC Actions Showcase Expansive U.S. Oversight of Foreign Conduct

Whiteford on

The U.S. Department of Justice (DOJ) and the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) have recently announced two enforcement actions that demonstrate the U.S. government's aggressive and...more

Adams & Reese

International Compliance Digest – November 2024

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While the incoming administration has blanketed the news cycle with newly threatened tariffs against typical targets like China, and against neighboring allies like Canada and Mexico, the current administration has quietly...more

BakerHostetler

Weekly Blockchain Blog - September 2024 #4

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Payments Firms Launch Crypto Products, New Crypto Adoption Data Published - According to a recent press release, a well-known U.S. payments and financial technology company announced that it will allow its United States...more

Sheppard Mullin Richter & Hampton LLP

SoL Long to Short Limits: The Sequel — A Decade of Recordkeeping and Enforcement

On July 22, 2024, the Department of Treasury, Office of Foreign Assets Control (OFAC) announced a significant planned extension to its recordkeeping requirements, which will increase the retention period from five to ten...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

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

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

Cooley LLP

Tri-Seal Compliance Note Highlights Broad Reach of US Trade Controls, Obligations of Non-US Persons

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On 6 March 2024, the US Department of Commerce, Department of the Treasury and Department of Justice issued a Tri-Seal Compliance Note (compliance note) advising foreign-based companies and individuals to assess their...more

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – February 2024 Update

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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

Mayer Brown

US Agencies’ Tri-Seal Compliance Note Emphasizes Extraterritorial Reach of Sanctions and Export Control Obligations

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On March 6, 2024, the US Departments of Commerce (“Commerce”), Treasury (“Treasury”), and Justice (“DOJ”) released their latest Tri-Seal Compliance Note (“Note”), which focuses on the “Obligations of foreign-based persons to...more

Cadwalader, Wickersham & Taft LLP

U.S. Deploys Pincer Maneuver on Perceived Crypto Abuses

Crypto’s two calling cards, decentralization and anonymity, can lead to abuses, such as money laundering and tax evasion. The U.S. Treasury has long combatted crypto money laundering...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2024 Update

January saw continuing focus on Russia. First, the Commerce Department’s Bureau of Industry and Security (BIS) expanded export controls on certain goods for Russia and Belarus. Second, a U.S.-Israeli citizen was arrested for...more

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