News & Analysis as of

Office of Foreign Assets Control (OFAC) New Guidance

BakerHostetler

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

BakerHostetler on

In 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 sanctions imposed by...more

Foley Hoag LLP

OFAC Issues Guidance Concerning Statute of Limitations Extension

Foley Hoag LLP on

On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50 (the “Act”). By doing so, the statute of limitations (“SoL”) for violations, both criminal and civil, of IEEPA...more

The Volkov Law Group

OFAC Releases Guidance on Extended Statute of Limitations & Forthcoming Recordkeeping Changes

The Volkov Law Group on

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control...more

Fenwick & West LLP

OFAC Publishes Guidance on 10-Year Sanctions Violations Statute of Limitations

Fenwick & West LLP on

On July 22, 2024, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued guidance addressing the April 2024 extension of the statute of limitations for sanctions violations from five years to 10...more

Davis Wright Tremaine LLP

OFAC Provides Guidance on Extended Statute of Limitations

As we previously reported, effective April 24, 2024, the statute of limitations for most civil and criminal violations of the International Emergency Economic Powers Act (IEEPA) or the Trading with the Enemy Act (TWEA) has...more

BakerHostetler

Key Export Control Developments During the First Quarter of 2024

BakerHostetler on

The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

BakerHostetler

USDC Integrations Announced; Crypto Guidance Published by IRS, EU Banking Authority; Crypto Firm Consents to $8M Penalty; Illicit...

BakerHostetler on

USDC Report Published, Crypto Firms Announce USDC Integrations - Circle, the U.S. fintech company that manages the stablecoin USDC, recently released the “State of the USDC Economy” report, highlighting the “efforts to...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

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

Ballard Spahr LLP on

On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

BakerHostetler

Fintech Firms Launch New Products; Crypto Guidance Published by CFTC, EBA, UAE; OFAC Adds Public Keys to SDN List; CFTC, NY AG...

BakerHostetler on

Crypto Firms Announce New Product Launches in Custody, Stablecoins, Wallets - According to a recent press release, Prometheum Capital has received the first-ever approval from the Financial Industry Regulation Authority...more

BakerHostetler

ETH Staking Data Published; USDC Transfer Protocol Launches; OFAC Adds Public Keys to SDN List; DOJ Targets Crypto Market...

BakerHostetler on

ETH Staking Data Published, USDC Cross-Chain Transfer Protocol Launches - New data reflects that the recent amount of staking withdrawals on Ethereum has been balanced by a roughly equal amount of deposits. According to...more

Orrick, Herrington & Sutcliffe LLP

OFAC issues preliminary guidance on price cap policy implementation

On December 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced preliminary guidance on the implementation of the price cap policy for petroleum products of Russian Federation origin....more

Seward & Kissel LLP

OFAC Issues Determination and Guidance For Russian Oil Price Cap Policy Commencing Today

Seward & Kissel LLP on

As noted in our prior alerts (concerning OFAC’s September 9, 2022 preliminary guidance and October 31, 2022 follow-on FAQ clarifying the applicability of the impending price cap policy) the U.S. Department of the Treasury’s...more

Seward & Kissel LLP

OFAC Issues Preliminary Guidance on Implementation of Maritime Services Policy and Related Price Exception for Seaborne Russian...

Seward & Kissel LLP on

On September 9, 2022 OFAC issued a preliminary guidance on the Implementation of a Maritime Services Policy and Related Price Exception for Seaborne Russian Oil in furtherance of a policy established by a coalition of...more

Latham & Watkins LLP

Russia Sanctions Update: OFAC Issues Guidance on “New Investment” and Management Consulting Bans

Latham & Watkins LLP on

OFAC has also extended certain general licenses, while BIS has continued to restrict exports to Russia. This Client Alert is published in the context of ongoing developments and should be read in conjunction with the...more

Hogan Lovells

From 15 June the UK sanctions regime will be moving to a strict liability test

Hogan Lovells on

From 15 June 2022 the Economic Crime (Transparency and Enforcement) Act 2022 will introduce changes to the enforcement of UK sanctions laws that parallel enforcement powers held by the Office of Foreign Assets Control...more

The Volkov Law Group

United States and EU Expand Russian Sanctions and Export Controls

The Volkov Law Group on

In its continuing ratcheting of sanctions against Russia, the United States and the European Union have announced new sanctions and export controls to target additional industries and government officials.  In a new front,...more

Goodwin

California DFPI Issues Guidance to Financial Institutions Regarding Russia Sanctions

Goodwin on

On March 4, 2022, the California Department of Financial Protection and Innovation (DFPI) issued a reminder to its financial institution licensees regarding their obligations in light of the Russian invasion of Ukraine: ...more

Dorsey & Whitney LLP

President Biden Signs New Law Requiring U.S. Blockage of All Imports Made Wholly or Partly in Xinjiang, China

Dorsey & Whitney LLP on

President Biden signed into law on December 23 legislation that will, for the first time, require U.S. Customs and Border Protection (“CBP”) to detain all imports that are made wholly or partly in the Xinjiang Uyghur...more

Akin Gump Strauss Hauer & Feld LLP

Treasury to Companies: Time to Take Ransomware Reporting Seriously

On September 21, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an updated sanctions advisory, providing guidance to companies on sanctions compliance obligations related to ransomware...more

Faegre Drinker Biddle & Reath LLP

OFAC Issues Sanctions Compliance Guidance for Virtual Currencies

In October, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published new guidance for the virtual currency industry focusing on compliance with the financial industry’s obligations...more

White & Case LLP

OFAC Sanctions Compliance Guidance for the Virtual Currency Industry

White & Case LLP on

On October 15, 2021, the US Department of the Treasury’s Office of Foreign Assets Control ("OFAC") issued a brochure to promote sanctions compliance in the virtual currency industry (the "Guidance")1 and updated two related...more

Foley Hoag LLP - Security, Privacy and the...

OFAC Publishes New Guidance for the Virtual Currency Industry

The U.S Department of the Treasury’s Office of Foreign Assets Control (OFAC) has published guidance to aid members of the virtual currency industry (ranging from tech companies to brokers to users) in complying with OFAC...more

Fisher Phillips

Federal Authorities Warn Employers Against Ransomware Payouts and Offer New Guidance on Preventing and Responding to Cyberattacks

Fisher Phillips on

Federal officials have recently warned employers and businesses that they could have insult added to injury if they respond to cyberattacks by making ransomware payments – increasingly requested through cryptocurrency – as...more

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