News & Analysis as of

Office of Foreign Assets Control (OFAC) Export Controls Sanctions

Foley & Lardner LLP

The Non-Compliant Cat in the Hat

Foley & Lardner LLP on

So, just before Easter, in 1957, a little book you may have heard of, called The Cat in the Hat, made its first appearance. Theodore Geisel — writing under the name “Dr. Suess” — later said that of all his children’s books,...more

Seward & Kissel LLP

President Trump Seeks “Maximum Pressure” on Iran Through Expansion of Sanctions Targeting Iran’s Oil Exports

Seward & Kissel LLP on

As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...more

Akin Gump Strauss Hauer & Feld LLP

National Security Presidential Memorandum/NSPM-2 (Trump EO Tracker)

Imposes maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist groups. Relevant Secretaries are required to impose and enforce sanctions,...more

J.S. Held

Engaging With Chinese Companies: Managing ‘Proxy Sanctions’ Risk

J.S. Held on

We are entering a year of acute political risk for international trade, with a high likelihood that the Trump administration will hit China with punitive tariffs and increased export controls. Against the backdrop of trade...more

Skadden, Arps, Slate, Meagher & Flom LLP

Political Changes Are Unlikely To Fundamentally Alter Key Sanctions

Key Points - - Political transitions in the West notwithstanding, we expect economic sanctions to remain a key response to geopolitical issues. - Current sanctions policy priorities are unlikely to shift markedly in...more

Katten Muchin Rosenman LLP

OFAC Sanctions Russia's Energy Sector

In an effort to reduce Russian energy revenues being used to fund the war against Ukraine, on January 10, 2025, the United States Department of the Treasury's Office of Foreign Assets Control (OFAC), issued a “determination”...more

ArentFox Schiff

OFAC Relaxes Sanctions Against Post-Assad Syria – For Now

ArentFox Schiff on

The US government signals careful optimism with a new general license authorizing some previously prohibited transactions, including many (but not all) transactions with Syrian governing institutions, for the next six months....more

Torres Trade Law, PLLC

Application of the Substantial Transformation Principle in the Context of U.S. Sanctions

Torres Trade Law, PLLC on

The practice of determining an item’s country of origin (“COO”) and utilizing the principal of “substantial transformation” to help make this determination is likely a familiar concept for many U.S. importers in the context...more

White & Case LLP

Sanctions move up the agenda for lenders and borrowers

White & Case LLP on

Compliance with sanctions regimes has been a priority for debt markets. Amid rising geopolitical tensions, the stakes for lenders and borrowers are higher than ever - Intensifying geopolitical tensions and the US...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – March 2024 Update

You are reading the March 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. Overview...more

WilmerHale

U.S. Agencies Caution Foreign-Based Persons on Extraterritorial Reach of U.S. Sanctions and Export Control Regulations

WilmerHale on

On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more

A&O Shearman

U.S. Imposes New Russia Sanctions and Export Controls and Warns of Risk of Continued Business with Russia

A&O Shearman on

On February 23, 2024, the United States imposed its largest number of new sanctions and export control designations against Russia to date—targeting over 600 individuals and entities across a wide swath of the Russian economy...more

Estlund Law, P.A.

Estlund Law Obtains A Dismissal Of All Charges For Client Charged With Violating Iranian Sanctions Regulations Under The...

Estlund Law, P.A. on

Miami, Florida, U.S.A.- Estlund Law client Dr. Faezeh Faghihi has spent her life in the service of others as a physician in her native Iran and in the United States, her adopted home country. Trained as a gynecologist, she...more

K2 Integrity

2023 in Review: An Eventful Year in Sanctions and Enforcement

K2 Integrity on

The sanctions world experienced another action-packed year in 2023. Sanctions against Russia dominated the year in terms of the number of designations and new restrictions, and the attacks perpetrated by Hamas in Israel on 7...more

Keating Muething & Klekamp PLL

Emerging State Laws Restricting Foreign Ownership of Real Estate

The Office of Foreign Assets Control (“OFAC”) is an arm of the U.S. Department of Treasury, tasked with administering and enforcing various economic and trade sanctions intended to further U.S. foreign policy and national...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFAC Enforcement Action Emphasizes the Importance of Whistleblower Programs

On August 16, 2023, OFAC announced a $660,594 settlement with Construction Specialties Inc. (CS) for alleged violations of the Iranian Transactions and Sanctions Regulations (ITSR). OFAC found that CS’s wholly controlled...more

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

Fenwick & West LLP on

On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more

Foley Hoag LLP

The Voluntary Disclosure Landscape After Microsoft’s Settlements with BIS and OFAC and the Issuance of the Axelrod Memorandum

Foley Hoag LLP on

On April 6, 2023, Microsoft Corporation (“Microsoft”) agreed to pay $3.3 million to the Department of Commerce’s Bureau of Industry and Security (“BIS”) and the Department of the Treasury’s Office of Foreign Assets Control...more

White & Case LLP

On Anniversary of Russia’s Invasion of Ukraine, US Announces Additional Sanctions and Export Controls, Imposes Higher Tariffs

White & Case LLP on

On the one-year anniversary of Russia's invasion of Ukraine, the US imposed additional sanctions and export controls measures on Russia. The restrictions include a new determination targeting the metals and mining sector of...more

Seward & Kissel LLP

Importance of Timely Sanctions Screening and Due Diligence

Seward & Kissel LLP on

The United States sanctions regime is a complex and ever-changing regulatory space. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) maintains sanctions lists which are updated in real-time—not on...more

Wilson Sonsini Goodrich & Rosati

License Exception ENC Severely Limited for Exports to Russia and Belarus, Belarus Targeted by Biden’s Third Tranche of Controls,...

The Biden administration took further action this week to degrade the ability of Belarus and Russia to sustain a military campaign against Ukraine. The measures are the latest in a series of restrictions levied by the U.S. in...more

Husch Blackwell LLP

U.S. Government Signals that Increased Sanctions and Export Controls Will Likely Follow if Russia Invades Ukraine

Husch Blackwell LLP on

Russia has amassed more than 100,000 troops at the Ukrainian border, leading the White House to issue a warning on January 25 that the U.S. is “prepared to implement sanctions with massive consequences that were not...more

Lowenstein Sandler LLP

Trade Matters, February 2022: A monthly newsletter covering global trade & national security developments

1. Treasury Mandates Reporting of Foreign Securities Holdings of $200M or More- All U.S. persons (custodians and end investors) who manage $200 million or more in foreign securities for themselves or others must file a...more

Akin Gump Strauss Hauer & Feld LLP

Ukraine-Russia Crisis: Possible New Sanctions and Export Controls on Russia and Potential Implications for U.S. and Non-U.S....

Key Points - The United States, European Union, United Kingdom and other U.S. allies are currently considering a range of severe economic measures against Russia to impose in the event of a Russian military incursion into...more

Wiley Rein LLP

U.S. Sanctions Individuals for ‘Destabilization Activities in Ukraine’; Is Prepared to Impose Harsher Measures

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On January 20, 2022, the U.S. Department of the Treasury’s (Treasury) Office of Foreign Assets Control (OFAC) sanctioned four individuals who are acting at the direction of the Russian Federal Security Service (FSB) to...more

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