News & Analysis as of

Office of Foreign Assets Control (OFAC) Economic Sanctions

Husch Blackwell LLP

The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and...

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Host Gregg N. Sofer welcomes Husch Blackwell partner Grant Leach to the program to discuss the burgeoning set of requirements and restrictions placed on U.S. businesses in connection with trade law. Gregg and Grant identify...more

Adams and Reese LLP

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

WilmerHale

China, the United States, and the Rivalry Over the Imposition of Unilateral Trade Sanctions

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China has long maintained that trade sanctions imposed unilaterally by one or more countries outside the scope of the United Nations Security Council, where China enjoys veto power as one of the five permanent members, are...more

Dorsey & Whitney LLP

Biden Administration Again Expands Sanctions on Russia and Its Third Party Supporters

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As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...more

Locke Lord LLP

What Do Diamonds, Safety and the Environment Have in Common? OFAC New General Licenses and FAQs

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On August 23, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 103 ("Authorizing Transactions Related to Imports of Certain Diamond Jewelry Prohibited by...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024 #2

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In its continuing response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic...more

BakerHostetler

Current State of U.S. Export Controls in Response to the Russian Federation’s Invasion of Ukraine - August 2024

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In a continued effort to hinder Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. ...more

Locke Lord LLP

OFAC Extends and Issues General Licenses Involving Russian Tax and Civil Aviation Safety

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The U.S. Department of the Treasury’s Office of Foreign Asset Control ‎‎(“OFAC”) on (i) July 10, 2024, extended General License (“GL”) 13J (“Authorizing Certain Administrative Transactions Prohibited by Directive 4 under...more

Locke Lord LLP

OFAC Continues Restrictions Blocking ‎Enforcement of CITGO-Backed PdVSA Bonds

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An August 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) further delayed to November 12, 2024, U.S. persons’ rights as bondholders of Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5%...more

Locke Lord LLP

OFAC Releases Initiatives to Enhance ‎Public Guidance on ‎Sanctions Implementation

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On August 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a series of new initiatives to assist the public to better understand sanctions and the role of the private sector...more

Kelley Drye & Warren LLP

Commerce, Treasury, and State Announce Measures Targeted at Further Restricting Russia and Belarus

On August 23, 2024, the U.S. Departments of Commerce, Treasury, and State published new restrictions on Russia aimed at further limiting its access to U.S. materials and international procurement networks for its military....more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024

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In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more

Locke Lord LLP

OFAC Extends General License to Allow ‎Export Liquefied Petroleum ‎Gas to PdVSA for Humanitarian Aid

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The Venezuela Sanctions Regulations, 31 CFR Part 591 (“VSR”), which was enacted pursuant to Executive Order (“EO”) 13850 of November 1, 2018 (“Blocking Property of Additional Persons Contributing to the Situation in...more

Locke Lord LLP

OFAC Extends General License for GL ‎‎99A Entities and Issues New GL for VPower in Hong Kong

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On August 2, 2024, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License ("GL") 99A, which authorizes through October 12, 2024, the wind-down of transactions...more

The Volkov Law Group

U.S. Sanctions Update as of April 2024

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U.S. Persons prohibited from transactions with anyone on the OFAC SDN List without a license, regardless of country. Includes entities owned in excess of 50-percent by one or more SDNs (33-percent for select Russian...more

Locke Lord LLP

OFAC Limits Exports of Technology to Russia ‎‎‎and Expands Secondary Sanctions on FFIs That Support ‎Russian War ‎Efforts

Locke Lord LLP on

On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new Determination Pursuant to Section 1 (a)(ii) of Executive Order 14071 (the “Determination”)‎ that prohibits U.S....more

The Volkov Law Group

EU Revises Restrictive Measure “Best Practices” to Account for Adoption of OFAC 50% Rule Equivalent

The Volkov Law Group on

On July 3, 2024, the Council of the European Union (“EU Council”) officially promulgated a new set of best practices (“best practices” or “guidance”) for organizations seeking to comply with the latest sanctions regulations...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

Blank Rome LLP

Key Takeaways from OFAC’s New Standards for Document Submissions

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently issued updated guidance on standards and requirements for document production submissions. This guidance is a significant step forward...more

Adams and Reese LLP

International Compliance Digest – July 2024

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July was a big month for compliance with a handful of reports and recommendations on due diligence and best practices concerning forced labor, export controls, sanctions from DHS, BIS, and OFAC. The below updates also...more

Blank Rome LLP

OFAC Guidance on Extending the Statute of Limitations for Sanctions Violations Signals Aggressive Enforcement

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) last week issued guidance regarding the extension of the statute of limitations for sanctions violations. This guidance follows the enactment of...more

Faegre Drinker Biddle & Reath LLP

New (and Extended) Statute of Limitations for Many Sanctions Violations Enforced by OFAC

New OFAC Guidance on Statute of Limitations - On July 22, 2024, the Office of Foreign Assets Control (OFAC) published new guidance addressing how it intends to apply a recent change in the statute of limitations for...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

Hogan Lovells

OFAC issues statute of limitations guidance for US sanctions violations and recordkeeping

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The US Department of the Treasury’s Office of Foreign Assets Control has released guidance following on Congress’ extension of the statute of limitations for violations of certain sanctions and related recordkeeping...more

Seward & Kissel LLP

Compliance Flash: OFAC Announces New Reporting Requirement for Financial Institutions Under the REPO for Ukrainians Act

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The supplemental appropriations legislation signed into law on April 24, 2024 enacted numerous high-profile provisions addressing aspects of U.S. foreign policy and national security, including provisions that broaden and...more

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