News & Analysis as of

Office of Foreign Assets Control (OFAC) Executive Orders

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

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

BakerHostetler

DOJ Implements Bulk Personal Data Transfer Restrictions

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The Data Security Program (DSP) recently implemented by the U.S. Department of Justice (DOJ) will have far-reaching implications for many businesses that transfer the personal data of U.S. citizens outside the United States....more

Husch Blackwell LLP

Week Twelve in Trade – First 100 Days of the New Administration

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On April 8, 2025, President Trump issued an Executive Order raising the reciprocal tariff rate on Chinese imports from 34% to 84%. This move followed his earlier warning that the U.S. would impose a 50% increase unless China...more

Bracewell LLP

Post Liberation Day --"Secondary Tariffs" Raise Costs Even Higher for International Actors

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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

Miller Canfield

DOJ Rule Restricting Sensitive Data Transfers Takes Effect

Miller Canfield on

Today, April 8, 2025, the U.S. Department of Justice’s Final Rule restricting transfers of bulk sensitive personal data and U.S. government-related data becomes effective, implementing former President Biden’s Executive Order...more

Paul Hastings LLP

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

Paul Hastings LLP on

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

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

A&O Shearman

Widening the sanctions net in uncertain times: latest developments in the U.S., EU, and U.K.'s sanctions targeting Russia

A&O Shearman on

In the context of the third anniversary of Russia’s invasion of Ukraine, the U.S., EU, and U.K. continue to implement new measures to stifle Russia’s war efforts. The Biden administration continued to escalate sanctions...more

BakerHostetler

Weekly Blockchain Blog - March 2025 #2

BakerHostetler on

Executive Order Establishes Strategic Bitcoin Reserve, Digital Asset Stockpile - On March 6, President Trump issued an executive order (EO), Establishment of the Strategic Bitcoin Reserve and United States Digital Asset...more

K2 Integrity

Escalation Against Cartels: U.S. Designates International Cartels as Foreign Terrorist Organizations and Specially Designated...

K2 Integrity on

On 20 February 2025, the United States (U.S.) Department of State designated eight international cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The designation of...more

Bracewell LLP

Trump Administration Makes First Round of Cartel Foreign Terrorist Organization Designations with Focus on Mexico and Venezuela

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The US State Department has made its first round of designations pursuant to Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists,”...more

Latham & Watkins LLP

Trump Administration Targets Cartels With First Wave of Terrorism Designations

Latham & Watkins LLP on

The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....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

Holland & Knight LLP

Trump Administration Announces Designation of International Cartels

Holland & Knight LLP on

U.S. President Donald Trump issued Executive Order 14157 (the EO) on Jan. 20, 2025, calling for the designation of drug cartels and other foreign organizations as foreign terrorist organizations (FTOs) or specially designated...more

Hogan Lovells

U.S. State Department reinstates Cuba Restricted List

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The U.S. Department of State has formally republished the Cuba Restricted List, restoring prohibitions on direct financial transactions with numerous Cuban military, intelligence, and security-linked entities. This move...more

White & Case LLP

DOJ Implements Major Changes to National Security Priorities

White & Case LLP on

On February 5, 2025, President Trump's nominee to lead the Justice Department (the "Department"), Pamela Bondi, was confirmed by the Senate to serve as the U.S. Attorney General. Bondi immediately took action to reshape the...more

Bracewell LLP

Guiding Your Company Through Trump’s New Latin America Enforcement Policy

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Shortly after President Trump’s second inauguration, his executive branch took steps to further one of his signature promises: securing the southern border. While these actions primarily impact immigration laws, several...more

Woods Rogers

Designating Cartels as Terrorists: Potential Impact on U.S. Businesses

Woods Rogers on

On his first day in office, President Trump signed an executive order (EO 14157) that sets in motion the designation of certain cartels and transnational crime gangs as terrorist organizations. The President declared a...more

Husch Blackwell LLP

Week Three in Trade – First 100 Days of the New Administration

Husch Blackwell LLP on

We previously covered President Trump’s IEEPA tariffs and the various retaliatory tariff and nontariff countermeasures announced by each country in separate posts. Currently, the Mexico and Canada tariffs have been paused...more

Alston & Bird

President Trump Renews “Maximum Pressure” Approach to Iran

Alston & Bird on

President Trump issued a new Executive Order renewing a commitment to imposing “maximum pressure” on the Iranian government to “end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist...more

Akin Gump Strauss Hauer & Feld LLP

Imposing Sanctions on the International Criminal Court (Trump EO Tracker)

Order imposes financial sanctions and visa restrictions against International Criminal Court (ICC) officials and their family members who assisted in targeting America and Israel. Within 60 days of the date of this order, the...more

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