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Office of Foreign Assets Control (OFAC) Regulatory Requirements

BakerHostetler

DOJ Implements Bulk Personal Data Transfer Restrictions

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The Data Security Program (DSP) recently implemented by the U.S. Department of Justice (DOJ) will have far-reaching implications for many businesses that transfer the personal data of U.S. citizens outside the United States....more

Troutman Pepper Locke

Navigating 2025: Trends in OFAC and DOJ Enforcement for Digital Assets — The Crypto Exchange Podcast

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In this episode of Crypto Exchange, host Ethan Ostroff is joined by his colleagues Pete Jeydel and Peter Leary to discuss trends and lessons learned from recent civil enforcement actions by the Treasury Department's Office of...more

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

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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

Morgan Lewis

US Designation of Cartels as Terrorist Organizations Increases Risk of Doing Business in Mexico

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Recent US government actions indicate a possible increase in US financial crimes investigations and enforcement targeting drug cartels and transnational criminal organizations in Latin America....more

Lowenstein Sandler LLP

Crypto Brief - Lowenstein Crypto Newsletter - March 20, 2025

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Lowenstein Crypto advises leading digital asset and cryptocurrency projects, exchanges, and trading firms. Our practice covers regulatory advice, transactions and structuring advice, investigations, and adversarial matters...more

Seward & Kissel LLP

OFAC Announces Wind Down of Chevron’s Oil Operations in Venezuela

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On March 4, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 41A, “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint...more

Arnall Golden Gregory LLP

OFAC and KoFIU Sanctions Compliance for Financial Technologies Companies

As financial technologies companies expand operations across borders, understanding the sanctions regimes of both the United States and South Korea becomes essential. The U.S. Treasury Department’s Office of Foreign Assets...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

American Conference Institute (ACI)

[Event] Advanced Forum on Global Export Controls - February 25th - 26th, Arlington, VA

Looking for something more advanced than your average export controls conference? Go beyond the basics at ACI’s 2nd Annual Advanced Forum on Global Export Controls. This premier event offers cutting-edge insights and...more

A&O Shearman

DOJ/CISA finalize new rules regarding data transfers to countries of concern

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On December 27, 2024, the U.S. Department of Justice (DOJ) announced its final rule on the transfer of certain bulk sensitive personal data to China, Russia, and other countries. Following this, on January 3, 2025, the U.S....more

The Volkov Law Group

C.H. Robinsom Settles with OFAC for $257,690 to Resolve Iran and Cuba Sanctions Violations

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C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more

The Volkov Law Group

BIS Reaches $180,000 Mitigated Settlement with Indium Corporation Over Illegal Exports to Russia

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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a Final Order against The Indium Corporation of America, citing eleven (11) alleged violations of the Export Administration Regulations...more

Morrison & Foerster LLP

M&A in 2024 and Trends for 2025

Global M&A in 2024 faced geopolitical issues, elevated interest rates, and inflationary pressures, with expanding antitrust, foreign investment, national security, and export regimes adding complexity. But inflation receded...more

Troutman Pepper Locke

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

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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

Conyers

Navigating International Sanctions: Impact of the Ukraine War on Bermuda

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When Russia invaded Ukraine on 22 February 2022 most Bermudian residents did not think it would have much impact to the island. However as both an overseas territory of the United Kingdom and as an international finance...more

Torres Trade Law, PLLC

The Mergers & Acquisitions Review: US Trade Compliance Due Diligence 2024

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In addition to a myriad of issues to consider during M&A transactions, parties should conduct due diligence related to US trade regulations and the often-related foreign investment regulations that arise in the context of an...more

Foley Hoag LLP

OFAC Publishes Updated Maritime Oil Industry Advisory

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On October 21, 2024, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) issued an Updated Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors (“Updated Advisory”). OFAC...more

King & Spalding

Ten-Year Statute of Limitations for Sanctions Violations Update

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As discussed in our May 7, 2024 alert, on April 24, 2024, President Biden signed into law a foreign military support package (i.e., H.R. 815), which included a provision doubling the statute of limitations (“SOL”) from five...more

Seward & Kissel LLP

Compliance Flash: Reminder to File the 2024 Annual Report of Blocked Property with OFAC

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Each year, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) requires all holders of blocked property to submit an Annual Report of Blocked Property (“ARBP”) setting forth all blocked...more

White & Case LLP

The Shadow Financial System

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The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

The Volkov Law Group

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

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On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls...more

WilmerHale

BIS Adds New License Exception for Medical Devices to Russia, Belarus and Occupied Regions of Ukraine

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Medical device companies have a new regulatory pathway for exporting certain U.S.-origin medical products to Russia, Belarus, Crimea and other regions of Ukraine (i.e., the so-called Donetsk People’s Republic and Luhansk...more

Jenner & Block

Client Alert: White House Executive Order Seeks to Protect Americans’ Sensitive Personal Data and US Government-Related Data in...

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On February 28, 2024, President Biden issued Executive Order 14117 on Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern (the EO). The EO empowers...more

Cadwalader, Wickersham & Taft LLP

U.S. Deploys Pincer Maneuver on Perceived Crypto Abuses

Crypto’s two calling cards, decentralization and anonymity, can lead to abuses, such as money laundering and tax evasion. The U.S. Treasury has long combatted crypto money laundering...more

Akin Gump Strauss Hauer & Feld LLP

DoD Updates Section 1260H List of Chinese Military Companies Operating Directly or Indirectly in the United States

Key Points - On January 31, 2024, the Department of Defense (DoD) released an update to its list of “Chinese military companies” that are “operating directly or indirectly in the United States” in accordance with the...more

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