News & Analysis as of

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

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

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

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

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

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

Troutman Pepper Locke

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

Troutman Pepper Locke 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

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

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

Faegre Drinker Biddle & Reath LLP

President Trump Imposes Sanctions on Companies Doing Business with Iran’s Construction, Mining, Manufacturing and Textiles...

On January 10, 2020, President Trump issued a new Executive Order that imposes the latest in a series of economic sanctions on Iran. Individuals and entities violating these and other sanctions on Iran can face significant...more

Hogan Lovells

U.S. government announces enhanced due diligence process for humanitarian trade with Iran and identifies Iran as a jurisdiction of...

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On 25 October the U.S. Departments of the Treasury and State announced the establishment of a new channel for conducting due diligence on humanitarian trade with Iran. Foreign governments and foreign financial institutions...more

Hogan Lovells

U.S. government issues new executive order targeting Turkey and sanctions the Turkish Ministry of Defense, Ministry of Energy and...

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On 14 October, President Donald Trump issued Executive Order 13894, Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria (EO). ...more

Akin Gump Strauss Hauer & Feld LLP

Trump Administration Expands Sanctions Targeting Iran’s Industrial Metals Sector

• President Trump issued a new Executive Order (EO) on May 8, 2019—exactly one year after the Trump administration withdrew from the Iran nuclear deal—that widened the scope of existing sanctions targeting the Iranian...more

Holland & Knight LLP

Ambassador Bolton Warns of Potential U.S. Secondary Sanctions Against Venezuela - Non-U.S. Entities Transacting with Certain...

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• National Security Advisor Ambassador John Bolton issued a statement threatening sanctions against non-U.S. banks for facilitating illegitimate transactions with certain Venezuelan individuals and entities. • This...more

Akin Gump Strauss Hauer & Feld LLP

Iran Sanctions Are Here—Breaking Down What This Means For Business

• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more

Sheppard Mullin Richter & Hampton LLP

Client Alert: Iran Sanctions Are Back On: Can Business Continue?

On May 8, 2018, the United States withdrew from the Joint Comprehensive Plan of Action and reimposed all pre-JCPOA sanctions against Iran... After a prescribed wind-down period, all U.S. sanctions on Iran are now in force....more

Sheppard Mullin Richter & Hampton LLP

Client Alert: Iran Sanctions Return

1. All sanctions on Iran that were in place before January 2016 will be re-imposed no later than November, 4 2018. 2. Secondary sanctions that penalize non-U.S. persons doing business with Iran will be reinstated. 3....more

Holland & Knight LLP

How Will the United States’ Withdrawal From the Iran Nuclear Accord Affect the Aviation Industry?

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On May 8, President Trump announced that the United States is withdrawing from the multilateral nuclear accord with Iran known as the Joint Comprehensive Plan of Action (JCPOA). The U.S. will reimpose sanctions suspended...more

Akin Gump Strauss Hauer & Feld LLP

President Trump Announces U.S. Withdrawal from JCPOA; U.S. Sanctions on Iran will be Re-imposed Following Wind-Down Periods

• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more

Akin Gump Strauss Hauer & Feld LLP

Implementing CAATSA - OFAC Issues Amended Russian-Related Sectoral Sanctions Under Directives 1 and 2

On September 29, 2017, OFAC modified Directives 1 and 2 of Executive Order 13662 to reduce the permissible maturity for new debt issued by Russian financial and energy entities designated under these directives, as well as...more

Akin Gump Strauss Hauer & Feld LLP

Trump Administration Significantly Expands Sanctions Against North Korea

On September 21, 2017, the White House announced additional sanctions against North Korea, following a new round of sanctions imposed by the United Nations on September 11 and an escalation of U.S. sanctions previously...more

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