News & Analysis as of

Office of Foreign Assets Control (OFAC) Enforcement Actions

The Volkov Law Group

Lessons Learned from the Unicat Settlement (Part III of III)

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The Unicat settlement provides some important insights into the Trump Administration’s direction on trade enforcement. It underscores the importance of voluntary disclosure, cooperation and remediation, the tri-part...more

The Volkov Law Group

Unicat Settles with DOJ and Resolves Sanctions, Export Controls and Customs Violations Applying Voluntary Disclosure Policy in M&A...

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In an interesting enforcement action reflecting the Administration’s priority on sanctions, export and customs enforcement, DOJ announced a global resolution with DOJ, OFAC, BIS and CBP and Unicat Catalyst Technologies...more

King & Spalding

Recent OFAC and DOJ Activity Signals Potential New Era of Control-Based Sanctions Enforcement

King & Spalding on

U.S. sanctions enforcement is evolving to adopt a “control” analysis similar to the analysis employed by the European Union and United Kingdom based on a recent major enforcement action by the U.S. Department of the...more

The Volkov Law Group

OFAC Returns to Enforcement Scene — GVA Capital Pays $215 Million Penalty for Violations of Ukraine/Russia-Sanctions

The Volkov Law Group on

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been relatively quiet on the enforcement front. That is not unusual — every transition results in an enforcement hiatus. Sanctions enforcement is a...more

White & Case LLP

DOJ Declines to Prosecute Private Equity Firm after Post-Acquisition Voluntary Self-Disclosure of Sanctions and Export Control...

White & Case LLP on

In its first application of the policy on voluntary self-disclosures (“VSDs”) in connection with mergers and acquisitions (“M&A”), on June 16, 2025, the US Department of Justice’s (“DOJ”) National Security Division (“NSD”)...more

Akin Gump Strauss Hauer & Feld LLP

Acquirors Beware: PE Firm Escapes DOJ Prosecution, but Acquired Entity Hit With $2 million+ in Penalties

In March 2024, NSD issued an updated Enforcement Policy for Business Organizations (NSD Enforcement Policy) that includes the M&A Policy.  Under the M&A Policy, where an acquiring company makes a qualifying voluntary...more

Mayer Brown

UK Weekly Sanctions Update - Week of June 16, 2025

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In this weekly update, we summarise the most notable updates in the UK sanctions world. Russia Sanctions UK government adds 10 new entries and specifies 20 ships under the Russia regime: On June 17, 2025, the UK government...more

Morgan Lewis

OFAC Action Shows Risk of Not Recognizing That ‘Property Interests’ Include ‘Any Interest Whatsoever’

Morgan Lewis on

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) fined GVA Capital Ltd. $215 million, primarily for violating the Ukraine/Russia-related sanctions regulations, when GVA mistakenly concluded that it...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … Mitigating Risks Posed by the New Trump Administration Focus on Drug Cartels...

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Print Share by Email Share Back to top The Trump Administration’s crackdown on cartels and transnational criminal organizations (TCOs) operating abroad and in the United States is a significant Department of Justice (DOJ)...more

Troutman Pepper Locke

Major OFAC Penalty for US Venture Capital Fund – Key Takeaways

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On June 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a civil penalty of approximately $216 million on GVA Capital Ltd., a venture capital firm based in San Francisco, for...more

Amundsen Davis LLC

How to Be Removed From a U.S. Sanctions Watchlist List

Amundsen Davis LLC on

U.S. sanctions are a powerful tool used to influence the behavior of foreign governments, individuals, and entities. Placement on any sanctions watchlist maintained by a regulatory agency can have devastating financial,...more

Morrison & Foerster LLP

Enforcement of China’s Anti-Foreign Sanctions Law Strengthens Through Private Cause of Action and New Implementing Rules

In November 2024, in the first successful private cause of action under the Anti-Foreign Sanctions Law (AFSL), a Chinese court adjudicated a civil claim by a Chinese company against its overseas customer for failure to pay...more

Stikeman Elliott LLP

Enforcement At Last: Charges Laid for Violating Canada’s Russia Sanctions

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A Russian expatriate with a Canadian-registered company has been charged by the RCMP under both the Special Economic Measures (Russia) Regulations (“Russia Regulations”) and the anti-money laundering provisions of the...more

Morrison & Foerster LLP

Terrorism Designations Primer: Process, Authorities, and Recourse

Since the mid-1990s, the Executive Branch has sought to target foreign terrorist organizations, and those individuals and organizations supporting them, in order to degrade their funding and support. Organizations and...more

Troutman Pepper Locke

DOJ’s Criminal Division Announces Updates to White-Collar Enforcement and Corporate Policies

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On May 12, 2025, the Head of the Criminal Division (the Criminal Division or Division) at the Department of Justice (DOJ), Matthew R. Galeotti, issued key memoranda to Criminal Division personnel on the Division’s new...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

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

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

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

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

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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

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

Paul Hastings LLP

A Whirlwind of Change: The Delisting of Tornado Cash

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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

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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