News & Analysis as of

Office of Foreign Assets Control (OFAC) National Security Sanctions

Bradley Arant Boult Cummings LLP

How the Trump Administration’s War on Cartels Will Reshape the Financial Sector

On March 11, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) aimed at disrupting drug trafficking and money laundering along the southwestern border. The...more

StoneTurn

Do You Know Who Your Employee Is? Mitigating DPRK IT Worker Risk

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North Korean IT operatives are infiltrating U.S. and Western companies using stolen or fabricated identities, VPNs, and U.S.-based co-conspirators to gain unauthorized access to corporate systems. These insider threats pose...more

Seward & Kissel LLP

President Trump Seeks “Maximum Pressure” on Iran Through Expansion of Sanctions Targeting Iran’s Oil Exports

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As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...more

Woods Rogers

Designating Cartels as Terrorists: Potential Impact on U.S. Businesses

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On his first day in office, President Trump signed an executive order (EO 14157) that sets in motion the designation of certain cartels and transnational crime gangs as terrorist organizations. The President declared a...more

Guidepost Solutions LLC

Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more

Akin Gump Strauss Hauer & Feld LLP

National Security Presidential Memorandum/NSPM-2 (Trump EO Tracker)

Imposes maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist groups. Relevant Secretaries are required to impose and enforce sanctions,...more

J.S. Held

Engaging With Chinese Companies: Managing ‘Proxy Sanctions’ Risk

J.S. Held on

We are entering a year of acute political risk for international trade, with a high likelihood that the Trump administration will hit China with punitive tariffs and increased export controls. Against the backdrop of trade...more

Pillsbury - Global Trade & Sanctions Law

Framework for Collaboration Between U.S. and UK Sanctions Authorities

Earlier this week, the U.S. Office of Foreign Assets Control (OFAC) and the UK Office of Financial Sanctions Implementation (OFSI) published a Memorandum of Understanding (MoU), which was previously signed on October 9, 2024,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Political Changes Are Unlikely To Fundamentally Alter Key Sanctions

Key Points - - Political transitions in the West notwithstanding, we expect economic sanctions to remain a key response to geopolitical issues. - Current sanctions policy priorities are unlikely to shift markedly in...more

Katten Muchin Rosenman LLP

OFAC Sanctions Russia's Energy Sector

In an effort to reduce Russian energy revenues being used to fund the war against Ukraine, on January 10, 2025, the United States Department of the Treasury's Office of Foreign Assets Control (OFAC), issued a “determination”...more

Bracewell LLP

Biden Administration Issues Sweeping Salvo of Sanctions Against the Russian Energy Sector

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On January 10, 2025, in a final action to, among other things, deter Russian aggression on the international stage, the US Department of the Treasury enacted sweeping new sanctions on the Russian energy sector. Specifically,...more

Alston & Bird

OFAC Announces Sanctions Against Chinese-Based Cybersecurity Company

Alston & Bird on

On January 3, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions on a Chinese-based cybersecurity company, Integrity Technology Group, Inc. (“Integrity Tech”). These sanctions...more

Ropes & Gray LLP

Russia/Ukraine Crisis: U.S. Targets Russia’s Energy Industry

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On January 10, 2025, the United States announced (another) major sanctions package targeting Russia, potentially representing the Biden administration’s last and best effort to strengthen Ukraine’s negotiating position in...more

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

Fenwick & West LLP on

On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more

Orrick, Herrington & Sutcliffe LLP

OFAC sanctions arms facilitator for attempted deals between North Korea and Russia

On March 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13551, against a Slovakian national for attempting to facilitate arms deals between Russia...more

Wiley Rein LLP

Biden Administration Sanctions Donetsk, Luhansk Regions of Ukraine

Wiley Rein LLP on

On February 21, 2022, President Joe Biden issued an Executive Order (EO) in response to Russian President Vladimir Putin’s ongoing “efforts to undermine the sovereignty and territorial integrity of Ukraine.” Referencing a...more

Akin Gump Strauss Hauer & Feld LLP

Ukraine-Russia Crisis: Possible New Sanctions and Export Controls on Russia and Potential Implications for U.S. and Non-U.S....

Key Points - The United States, European Union, United Kingdom and other U.S. allies are currently considering a range of severe economic measures against Russia to impose in the event of a Russian military incursion into...more

Morrison & Foerster LLP

U.S. Government Takes Increasingly Aggressive Actions Targeting Ransomware

Morrison & Foerster LLP on

On November 8, 2021, the U.S. Department of Justice (“DOJ”), U.S. Department of the Treasury (“Treasury”), and the U.S. Department of State (“State”) made several significant announcements regarding recent U.S. government...more

Lowenstein Sandler LLP

Trade Matters - November 2021

Lowenstein Sandler LLP on

1. New Cybersecurity Export Controls From BIS Go Into Effect in January - The Bureau of Industry and Security (BIS) has released an interim final rule establishing new export controls on certain cybersecurity items and...more

Akin Gump Strauss Hauer & Feld LLP

Treasury Publishes U.S. Sanctions Policy Review and Framework for Future Action

On October 18, 2021, the U.S. Treasury Department released a long awaited report on its first of its kind “top to bottom” review of U.S. economic and financial sanctions. The report does not make or recommend any immediate or...more

K2 Integrity

Treasury Releases 2021 Sanctions Review

K2 Integrity on

On October 18, 2021, the U.S. Department of the Treasury released the 2021 Sanctions Review (“the Review”), which delineates Treasury’s framework for employing economic sanctions and provides key recommendations on...more

Bracewell LLP

OFAC Ransomware Update

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On Friday, OFAC published a compliance guide aimed at the virtual currency industry, which promotes sanctions compliance amid the rise of ransomware attacks. Similar to OFAC’s recent advisory, this compliance guide is yet...more

Morrison & Foerster LLP

DOJ Announces Renewed Focus on Export Control and Sanctions Enforcement

Morrison & Foerster LLP on

In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“DOJ” or the...more

Lowenstein Sandler LLP

Trade Matters - August 2021

1. Biden Administration Trade Posture- The Biden administration is slowly and steadily reviewing the decisions of the Trump administration. So far, the administration has struck a deal with the EU to end the 17-year-old...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Amends Sanctions Targeting Investments in Securities of Chinese Companies

On June 3, 2021, President Joe Biden issued Executive Order 14032 (EO 14032) amending and, in effect, recasting Executive Order 13959 of November 12, 2020 (EO 13959), which restricted U.S. persons from purchasing and selling...more

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