News & Analysis as of

Office of Foreign Assets Control (OFAC) Economic Sanctions

Mayer Brown

Russia/Ukraine Sanctions Update - Month of April 2025

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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)

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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

Venable LLP

A Legal Whirlwind Settles: Treasury Lifts Sanctions on Tornado Cash

Venable LLP on

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

Bracewell LLP on

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

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

Paul Hastings LLP

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

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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

Bracewell LLP

Trump Administration Efforts to Eliminate Cartels Pose Heightened Risk for Financial Institutions

Bracewell LLP on

As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more

Torres Trade Law, PLLC

Torres Trade Trump Table

The table below presents a structured timeline of executive actions, policy directives, and trade-related decisions issued by President Trump’s administration from January 2025 to the present. It focuses on critical areas...more

Paul Hastings LLP

New US Sanctions and Ongoing OFAC Designations Enable the New Administration’s Policy Priorities

Paul Hastings LLP on

Policy change in Washington since the change in administration has been swift, dramatic in many areas and executed with unprecedented pace. One area, however, has been relatively stable in the administration’s first two...more

Troutman Pepper Locke

Unprecedented "Secondary Tariffs" for Oil Trade With Venezuela

Troutman Pepper Locke on

On April 2 — labeled “Liberation Day” by President Trump — the Trump administration is set to add a new sanctions-like boost to its tariff strategy, with a threat to impose unprecedented “secondary tariffs” of 25% on “all...more

Paul Hastings LLP

A Whirlwind of Change: The Delisting of Tornado Cash

Paul Hastings LLP on

Over the past several years, as U.S. regulators have grappled with the increasing use of cryptocurrency across a spectrum of legitimate and illegitimate commerce, the U.S. Department of Commerce’s Office of Foreign Assets...more

American Conference Institute (ACI)

Preparing for Latin American Sanctions

President Trump’s “America First Trade Policy” is creating new sanctions compliance risk for financial services institutions and companies in an area that historically has not received as much enforcement attention: drug...more

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

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On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more

American Conference Institute (ACI)

[Event] 19th Annual Flagship Conference on Economic Sanctions Enforcement and Compliance - April 30th - May 1st, Washington, DC

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

Morgan Lewis

US Designation of Cartels as Terrorist Organizations Increases Risk of Doing Business in Mexico

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Recent US government actions indicate a possible increase in US financial crimes investigations and enforcement targeting drug cartels and transnational criminal organizations in Latin America....more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

K2 Integrity on

On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

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

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