News & Analysis as of

Office of Foreign Assets Control (OFAC) Foreign Financial Institutions (FFI)

K2 Integrity

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

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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

Latham & Watkins LLP

Trump Administration Targets Cartels With First Wave of Terrorism Designations

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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

The Volkov Law Group

OFAC Designates Gazprombank for Inclusion on SDN List

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In a significant development underscoring the U.S. government’s continued efforts to counter Russia’s destabilizing activities, the U.S. Department of the Treasury recently announced the designation of Gazprombank as a...more

Paul Hastings LLP

Further Sanctions Aim to Sever Remaining Ties Between Russia and U.S. Financial System

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On November 21, 2024, the Biden Administration announced sweeping new sanctions targeting numerous Russian banks, financial institutions and officials, including one of the largest remaining unblocked Russian banks,...more

Hogan Lovells

U.S. Treasury announces new sanctions targeting Russian banks, warns foreign financial institutions from using Russian alternative...

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The U.S. Department of the Treasury’s Office of Foreign Assets Control has designated dozens of Russian banks including Gazprombank and issued an alert warning foreign financial institutions of the risk of U.S. sanction for...more

Seward & Kissel LLP

OFAC Takes More Aggressive Action to Deter Foreign Financial Institutions’ Participation in Russian Financial Sector

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On November 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took further action to restrict Russia’s access to the international financial system by designating Gazprombank Joint Stock...more

Hogan Lovells

FATF updates its grey list to add Algeria, Angola, Côte d’Ivoire, and Lebanon and remove Senegal

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The Financial Action Task Force (FATF) has updated its ‘grey list’ of jurisdictions under increased monitoring, removing Senegal and adding Algeria, Angola, Côte d’Ivoire, and Lebanon. The intergovernmental organization made...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

The Volkov Law Group

OFAC Amends SDN and SSI List Entries to Incorporate Secondary Sanctions Warnings

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On July 3, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had amended entries for a multitude of entities sanctioned under the Treasury’s Russian Harmful Foreign...more

WilmerHale

New Multi-Jurisdictional Sanctions Continue to Target Broad Scope of Activities With Russia

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In conjunction with the Group of Seven (G7) leaders meeting in Italy earlier this month, key jurisdictions issued the latest in a series of coordinated economic restrictions on Russia in light of its invasion of Ukraine in...more

Snell & Wilmer

OFAC’s Reach: Shockwaves in Russia’s Financial System and Global Trade

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The recently announced sanctions by the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) sent shockwaves through the Russian financial system, forcing the Moscow Exchange (MOEX) to halt trading of U.S....more

Holland & Knight LLP

OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

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Nearly six months after President Joe Biden signed an executive order (EO) authorizing secondary sanctions against Foreign Financial Institutions (FFIs) conducting or facilitating significant transactions with certain...more

Wiley Rein LLP

New U.S. Sanctions and Export Controls on Russia Target Foreign Financial Institutions, Business Software, Critical Industries

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The Biden Administration’s recent expansion of sanctions and export controls to counter Russian aggression will impact non-U.S. financial institutions and increase compliance risks for the business software sector and other...more

Morrison & Foerster LLP

The United States Imposes New Sanctions and Export Control Restrictions to Further Constrain Russia’s War Efforts, Including by...

On June 12, 2024, the United States took several hard-hitting sanctions- and export control-related actions intended to intensify pressure on the Russian government and hamper Russia’s ability to continue to support its war...more

K2 Integrity

Sanctions Against Russia: U.S. Increases Secondary Sanctions Risks for Foreign Financial Institutions, Expands Sanctions and...

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On 12 June 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued new measures to further isolate Russia’s...more

Seward & Kissel LLP

OFAC Issues New Wave of Russia Sanctions Expanding Secondary Sanctions Risk for Foreign Financial Institutions

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On June 12, 2024, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), in coordination with the U.S. Department of State, announced a new wave of Russia sanctions that significantly expand...more

Dorsey & Whitney LLP

Biden Administration Adds Sanctions Against Foreign Financial Institutions Supporting Russia’s Military-Industrial Base

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As the February 2022 Russian invasion of neighboring Ukraine approaches its second anniversary and as Russia has increasingly turned to covert relationships with third country providers to avoid U.S., European Union and other...more

Paul Hastings LLP

Daily Financial Regulation Update -- Tuesday, January 30, 2024

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January 29, 2024- The U.S. Department of the Treasury issued a finding and notice of proposed rulemaking (NPRM) that identifies an Iraqi bank that serves as a conduit for terrorist financing, as a foreign financial...more

Akin Gump Strauss Hauer & Feld LLP

New Executive Order Authorizes the Imposition of Secondary Sanctions on Foreign Financial Institutions Facilitating Russia’s...

Key Points - On December 22, 2023, President Biden issued E.O. 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.” Specifically, E.O. 14114, which amends E.O. 14024 and E.O. 14068,...more

Williams Mullen

New Russia Sanctions Target Foreign Financial Institutions, Expand Import Bans

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On December 22, 2023, President Biden issued Executive Order (EO) 14114, imposing significant new economic sanctions against Russia to address the ongoing national security threat posed by the country’s invasion of Ukraine...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - January 2024

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On December 11, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of Homeland Security, the Department of State’s Directorate of Defense Trade Controls (DDTC), and...more

Troutman Pepper Locke

U.S. Issues Warning to Foreign ‎Financial Institutions That Assist Russia’s War Machine

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On December 22, 2023, President Biden issued new Executive Order (“EO”) 14114, amending EO 14024 and EO 14068. The new EO grants the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) authority to...more

Vedder Price

Latest Round of Russia Sanctions Targets Foreign Financial Institutions Supporting Russia's Military-Industrial Base

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On December 22, 2023, President Biden issued Executive Order (E.O.) 14114 further addressing the Russian Federation’s (Russia) continued use of its military-industrial base to support its aggression against Ukraine and to...more

K2 Integrity

Sanctions Against Russia: U.S. Introduces New Russia-Related Sanctions Targeting Foreign Financial Institutions And Tightens Other...

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On 22 December 2023, the Biden administration issued Executive Order 14114, “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” (EO 14114), thereby amending EOs 14024 and 14068. The new EO...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – December 2023 Update

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December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more

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