News & Analysis as of

Office of Foreign Assets Control (OFAC) Foreign Policy SDN List

Troutman Pepper Locke

Financial Transactions Related to Russian Energy Now Prohibited: Expiration of OFAC ‎General License 8L

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On March 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) allowed General License (GL) 8L under the Russian Harmful Foreign Activities Sanctions Regulations to expire. As a result, broad OFAC...more

White & Case LLP

United States Designates Eight Cartels and Transnational Criminal Organizations

White & Case LLP on

Effective February 20, 2025, the United States Designated Eight Cartels and Transnational Criminal Organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs)....more

Troutman Pepper Locke

US Declares War on Cartels: Historic Terrorist Designations Reshape Sanctions Compliance Risks

Troutman Pepper Locke on

On February 20, 2025, the U.S. Departments of State and the Treasury designated eight Latin American drug trafficking cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), in...more

Hogan Lovells

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

Hogan Lovells on

The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more

Troutman Pepper Locke

A Minefield in Russia’s Energy Sector: Biden’s Final Sanctions Act May be Game-Changing

Troutman Pepper Locke on

Days before President Biden leaves the White House, the U.S. government has delivered a major blow against Russia. On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced...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

Troutman Pepper Locke

OFAC's Latest General Licenses and FAQs Related to Russian Sanctions

Troutman Pepper Locke on

On December 18, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 1B (Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue...more

The Volkov Law Group

OFAC Designates Gazprombank for Inclusion on SDN List

The Volkov Law Group on

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

Foodman CPAs & Advisors

BIS New Guidance for FI’s Best Practices

Foodman CPAs & Advisors on

On 10/9/24, the Bureau of Industry and Security (BIS) within the Department of Commerce has issued guidance aimed at financial institutions (FIs), outlining best practices for adherence to the Export Administration...more

Troutman Pepper Locke

Between a Claim and a Hard Place: OFAC Sanctions Preempt State Insurance Laws

Troutman Pepper Locke on

U.S. sanctions laws present complex conflicts with state insurance laws. While state laws govern the timely payment of claims and other insurance practices, U.S. sanctions administered by the U.S. Department of the Treasury’s...more

Constangy, Brooks, Smith & Prophete, LLP

You’ve been hit with ransomware. Think twice before you pay.

You've been hit by a ransomware attack, and a cybercriminal group is demanding a cryptocurrency payment in exchange for your data's safe return. Should you pay? Deciding whether to pay a ransom is an internal business...more

The Volkov Law Group

OFAC Fines U.S. Person $1 Million for Multiple Violations of Sanctions Regime Against Iran

The Volkov Law Group on

In one of the more notable enforcement actions of 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently imposed a $1,104,408 civil penalty on a U.S. person for 75 separate violations...more

Hogan Lovells

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

Hogan Lovells on

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

Foley Hoag LLP

U.S. Sanctions Roundup – October & November 2024

Foley Hoag LLP on

The Department of the Treasury's Office of Foreign Assets Control (“OFAC”) was active in October and November 2024. After issuing an Updated Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors on...more

Morgan Lewis

New OFAC FAQs Offer Guidance on Insurers’ OFAC Compliance Obligations

Morgan Lewis on

The US Office of Foreign Assets Control recently amended its insurance-related FAQ and issued two new FAQs. This focus on insurance-related guidance comes at the same time as an enforcement action targeting an insurer that...more

Hogan Lovells

US announces sanctions against Chinese entities assisting in Russian drone development

Hogan Lovells on

The Office of Foreign Assets Control of the US Department of Treasury imposed sanctions against three private entities and one individual for assisting in the development and production of Russia’s Garpiya series long-range...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

Morgan Lewis

OFAC Extends Reach Over Securities Held by Russia’s National Settlement Depository

Morgan Lewis on

OFAC’s new FAQ 1097, issued October 10, warns US investors of the need to block securities held at Russia’s National Settlement Depository (NSD), even if the securities or the issuer is not sanctioned. Even if the security is...more

Troutman Pepper Locke

OFAC Takes Action Against Russian ‎Political Disinformation and ‎New Sanctions Evasion Tactics

Troutman Pepper Locke on

Russian Political Disinformation Efforts - On September 4, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) designated 10 individuals and two entities as specially designated nationals...more

Troutman Pepper Locke

OFAC Issues Warning to Financial ‎Institutions & Insurers That ‎Provide Maritime Services in the ‎Mediterranean, Red Sea and...

Troutman Pepper Locke on

Iran and Syria Sanctions and Embargos On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued updated guidance to remind maritime support service providers that the...more

Dorsey & Whitney LLP

Biden Administration Again Expands Sanctions on Russia and Its Third Party Supporters

Dorsey & Whitney LLP on

As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024 #2

BakerHostetler on

In its continuing response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic...more

Troutman Pepper Locke

OFAC Extends and Issues General Licenses Involving Russian Tax and Civil Aviation Safety

Troutman Pepper Locke on

The U.S. Department of the Treasury’s Office of Foreign Asset Control ‎‎(“OFAC”) on (i) July 10, 2024, extended General License (“GL”) 13J (“Authorizing Certain Administrative Transactions Prohibited by Directive 4 under...more

The Volkov Law Group

U.S. Sanctions Update as of April 2024

The Volkov Law Group on

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

The Volkov Law Group on

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

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