News & Analysis as of

Office of Foreign Assets Control (OFAC) Enforcement Actions Appeals

Venable LLP

A Legal Whirlwind Settles: Treasury Lifts Sanctions on Tornado Cash

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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

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

A&O Shearman

Fifth Circuit Limits OFAC Authority Over Certain Cryptocurrency Products

A&O Shearman on

On November 26, 2024, the Fifth Circuit Court of Appeals held that the United States Office of Foreign Assets Control (“OFAC”) exceeded its authority by adding an entity that pools and anonymizes crypto transactions to OFAC’s...more

Adams & Reese

International Compliance Digest – November 2024

Adams & Reese on

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

Oberheiden P.C.

Ten Strategic Considerations for OFAC Appeals

Oberheiden P.C. on

The Office of Foreign Assets Control (OFAC) has oversight of financial transactions involving U.S. and foreign entities. It exercises this authority in several ways, including (i) through the administration of its various...more

The Volkov Law Group

Appellate Court Upholds OFAC Designation of Oleg Deripaska, a Major Oligarch

The Volkov Law Group on

The Office of Foreign Asset Control’s designation of an entity as a Specially Designated National (SDN) is the “kiss of death.”  Such designation not only has a direct impact on an SDN’s ability to engage in business but has...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - September 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2019

ANTICORRUPTION DEVELOPMENTS - Telecommunications Company Fined $12 Million for FCPA Violations - On August 29, 2019, The Securities and Exchange Commission (SEC) instituted ceaseand-desist proceedings against...more

The Volkov Law Group

OFAC Enforcement: The Epsilon Case and Third Party Risks

The Volkov Law Group on

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced the settlement of the Epsilon enforcement action. This case requires a theme song and there is none better than Trucking from Grateful...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2018

ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2017

ANTICORRUPTION DEVELOPMENTS - MTS Receives DOJ and SEC Declination Letters Concluding FCPA Investigations - On August 7, 2017, MTS Systems (MTS), a Minnesota based maker of test systems and industrial position...more

Bass, Berry & Sims PLC

Rare Court Case Sheds Light on U.S. Sanctions Enforcement

Bass, Berry & Sims PLC on

It is rare for companies to go to court to fight penalties imposed by the Office of Foreign Assets Control (OFAC) for violations of U.S. sanctions. It is even more rare for a court to make any sort of finding against the...more

Perkins Coie

Court Opinion on Liability for Re-Exports to Iran Spurs Practical Guidance for U.S. Exporters

Perkins Coie on

A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran? This update summarizes the...more

Goodwin

Financial Services Weekly News - June 2016 #3

Goodwin on

Regulatory Developments - OFAC Updates Frequently Asked Questions Regarding Lifting Sanctions on Iran - On June 8, the Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) updated its...more

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