News & Analysis as of

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

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

Dechert LLP

U.S. Sanctions Russian Financial Infrastructure

Dechert LLP on

On the eve of the 2024 Group of Seven (G7) Leaders’ Summit, the United States imposed new sanctions and export control measures against Russia further targeting sanctions evaders and, for the first time, the Russian...more

K2 Integrity

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

K2 Integrity on

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

Dorsey & Whitney LLP on

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

Williams Mullen on

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

Locke Lord LLP

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

Locke Lord LLP on

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

Vedder Price on

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...

K2 Integrity on

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

Bass, Berry & Sims PLC on

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

Orrick, Herrington & Sutcliffe LLP

U.S. Authorizes Sanctions on Foreign Financial Institutions That Support Russia’s Military-Industrial Base and Expands Scope of...

President Biden issued an executive order on December 22, 2023 targeting evasion of U.S. sanctions on Russia. Executive Order 14,114: Authorizes sanctions on foreign financial institutions (“FFIs”) determined to have...more

The Volkov Law Group

New Executive Order Expands Treasury’s Authority to Impose ‘Secondary Sanctions’ on Foreign Financial Institutions Involved in...

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On December 22, 2023, President Joseph R. Biden, Jr. issued an executive order—”Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities”—that subjects certain foreign financial institutions that...more

Foley Hoag LLP

Biden Administration Threatens Foreign Financial Institutions With Secondary Sanctions for Involvement in Certain Transactions...

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On December 22, 2023, President Biden issued a new Executive Order affecting foreign financial institutions and those importing certain goods into the U.S. In addition, OFAC provided related new and revised FAQs, as well...more

Blank Rome LLP

New U.S. Russia Sanctions Target Financial Support of Military-Industrial Base and Expand Ban of Seafood Imports

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The Biden Administration recently issued the latest round of U.S. sanctions against Russia, focusing on (1) secondary sanctions applicable to foreign financial institutions (“FFIs”) that engage in certain transactions in...more

Kelley Drye & Warren LLP

White House Broadens Restrictions on Russia by Authorizing Sanctions on Foreign Financial Institutions and Expanding the Import...

On December 22, 2023, President Biden signed Executive Order 14114, titled ​“Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities” (EO 14114), with a focus on holding foreign financial...more

Morrison & Foerster LLP

U.S. Authorizes Secondary Sanctions on Banks Supporting Russia’s Military-Industrial Base

After two years of aggressive sanctions against Russia for its ongoing war in Ukraine, the United States has broadly expanded those sanctions to threaten foreign financial institutions (FFIs) that support Russia’s...more

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