News & Analysis as of

Office of Foreign Assets Control (OFAC) International Emergency Economic Powers Act (IEEPA)

WilmerHale

Implications of EO 14157 and Recent “Foreign Terrorist Organization” and “Specially Designated Global Terrorist” Designations

WilmerHale on

On January 20, 2025, President Donald J. Trump signed Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists” (EO 14157)....more

Husch Blackwell LLP

Week Twelve in Trade – First 100 Days of the New Administration

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On April 8, 2025, President Trump issued an Executive Order raising the reciprocal tariff rate on Chinese imports from 34% to 84%. This move followed his earlier warning that the U.S. would impose a 50% increase unless China...more

Bracewell LLP

Trump Administration Efforts to Eliminate Cartels Pose Heightened Risk for Financial Institutions

Bracewell LLP on

As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

Troutman Pepper Locke on

On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

K2 Integrity on

On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more

Husch Blackwell LLP

Week Seven in Trade – First 100 Days of the New Administration

Husch Blackwell LLP on

The tariffs imposed by President Trump on Canada and Mexico under the International Emergency Economic Powers Act of 1977 (IEEPA) went into effect on March 4, 2025. Our initial posting on this development can be found here....more

Foley & Lardner LLP

What Every Multinational Company (Doing Business in Mexico) Should Know About … Mitigating Risks From ATA Scrutiny in a New...

Foley & Lardner LLP on

Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more

K2 Integrity

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

K2 Integrity on

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

Latham & Watkins LLP on

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

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

DLA Piper on

Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

Dorsey & Whitney LLP

Attorney General Bondi Reorients National Security Enforcement Resources to Focus on Illegal Immigration and Drug Trafficking

Dorsey & Whitney LLP on

Upon being sworn in on February 5, 2025, Attorney General Pamela Bondi immediately issued memoranda reorienting national security enforcement resources of the U.S. Department of Justice (“DOJ”) to focus on addressing illegal...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

Holland & Knight LLP

Executive Order: Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global...

Holland & Knight LLP on

Date Issued: Jan. 20, 2025 This executive order initiates the process of designating certain international cartels as Foreign Terrorist Organizations (FTOs) to address the rise in violence and terror across the western...more

Troutman Pepper Locke

Tornado Cash Whiplash – What’s Next for Sanctions?

Troutman Pepper Locke on

We find ourselves in the midst of a raucous debate among sanctions practitioners about the impact of the Fifth Circuit’s recent decision upholding a challenge against the sanctions the Office of Foreign Assets Control (OFAC)...more

Holland & Knight LLP

Trump Threatens Retaliatory Measures vs. Latin American Countries Refusing Repatriation Flights

Holland & Knight LLP on

President Donald Trump on Jan. 20, 2025, issued various immigration-related Executive Orders (EOs) and presidential actions that could have an immediate and lasting impact on Latin American countries. President Trump's...more

Venable LLP

Trump Administration Prepares to Levy Novel Tariffs

Venable LLP on

As anticipated from campaign promises, on Monday, January 20, President Donald Trump issued an executive order (EO) commencing the process to levy a host of new trade tariffs as part of his "America First Trade Policy." New...more

Akin Gump Strauss Hauer & Feld LLP

Designating Cartels And Other Organizations As Foreign Terrorist Organizations And Specially Designated Global Terrorists

This Order declares a national emergency under the International Emergency Economic Powers Act (IEEPA) to designate certain international cartels and other organizations as Foreign Terrorist Organizations or Specially...more

Troutman Pepper Locke

Unpacking the Fifth Circuit's Landmark Tornado Cash Decision — The Crypto Exchange Podcast

Troutman Pepper Locke on

In this episode of the Crypto Exchange, Ethan Ostroff is joined by colleagues Pete Jeydel and Matt Orso to discuss a recent landmark decision from the Fifth Circuit regarding Tornado Cash. The court ruled that the Office of...more

Hinch Newman LLP

DOJ Issues Rule Addressing Threat Posed by Foreign Adversaries’ Access to Americans’ Sensitive Personal Data

Hinch Newman LLP on

On Friday, December 27, 2024, the Justice Department issued a final rule to address “urgent national security risks posed by access to U.S. sensitive personal and government-related data from countries of concern and covered...more

BCLP

Fifth Circuit Rules OFAC Cannot Sanction Tornado Cash: Loper Bright Hamstrings OFAC’s Campaign Against Crypto Laundering

BCLP on

Shortly before Thanksgiving, a panel of the United States Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) did not have the authority to sanction Tornado Cash, which offers a...more

Husch Blackwell LLP

International Trade Law: 2024 Year in Review & Outlook for 2025

Husch Blackwell LLP on

Few areas will be as impacted by the incoming second Trump administration as international trade policy. Check out our team’s assessment of what the coming year may bring for trade regulation and enforcement. Husch...more

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - November 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

Bracewell LLP

An "Immutable" Force Meets an Immovable Object: OFAC's Crypto Loss at the Fifth Circuit

Bracewell LLP on

On November 26, 2024, the US Court of Appeals for the Fifth Circuit ruled that “immutable” smart contracts are not “property” for purposes of regulation by the US Department of the Treasury’s Office of Foreign Assets Control...more

Hogan Lovells

U.S. Appeals Court limits OFAC’s sanctions authority in cryptocurrency mixer case

Hogan Lovells on

The Fifth Circuit held that Tornado Cash, open-source computer code known as an immutable “smart contract”, is not “property” and thus cannot be subject to blocking sanctions pursuant to IEEPA and EO 13694....more

A&O Shearman

Fifth Circuit Limits OFAC Authority Over Certain Cryptocurrency Products

A&O Shearman on

On November 26, 2024, the Fifth Circuit Court of Appeals held that the United States Office of Foreign Assets Control (“OFAC”) exceeded its authority by adding an entity that pools and anonymizes crypto transactions to OFAC’s...more

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