News & Analysis as of

Office of Foreign Assets Control (OFAC) Software SDN List

Orrick, Herrington & Sutcliffe LLP

5th Circuit reverses and remands cryptocurrency software case stating OFAC exceeded its authority

On November 26, the U.S. Court of Appeals for the Fifth Circuit reversed and remanded a decision by the district court regarding the Office of Foreign Assets Control’s (OFAC) designation of a virtual currency mixer software...more

Wiley Rein LLP

New U.S. Sanctions and Export Controls on Russia Target Foreign Financial Institutions, Business Software, Critical Industries

Wiley Rein LLP on

The Biden Administration’s recent expansion of sanctions and export controls to counter Russian aggression will impact non-U.S. financial institutions and increase compliance risks for the business software sector and other...more

Dechert LLP

U.S. Sanctions Russian Financial Infrastructure

Dechert LLP on

On the eve of the 2024 Group of Seven (G7) Leaders’ Summit, the United States imposed new sanctions and export control measures against Russia further targeting sanctions evaders and, for the first time, the Russian...more

K2 Integrity

Sanctions Against Russia: U.S. Increases Secondary Sanctions Risks for Foreign Financial Institutions, Expands Sanctions and...

K2 Integrity on

On 12 June 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued new measures to further isolate Russia’s...more

ArentFox Schiff

US Government Throws “Kitchen Sink” Export Controls at Russia, Plus Sweeping EAR99 Software Controls, and IT and Software Services...

ArentFox Schiff on

Three US agencies – the US Department of Commerce, Bureau of Industry and Security (BIS), the US Department of the Treasury, Office of Foreign Assets Control (OFAC), and the US Department of State – took new actions on June...more

Fenwick & West LLP

U.S. Imposes Sweeping New Sanctions and Export Controls on Russia and Belarus, including on Certain Software and Related Services

Fenwick & West LLP on

Citing Russia’s “transition to a full war economy,” the United States imposed sweeping new sanctions and export controls on Russia and Belarus today, including companies and individuals that continue to supply Russia’s...more

Dechert LLP

New Year's Resolution: Tackling Russian Sanctions Evasion

Dechert LLP on

Throughout December, the United States, European Union, and United Kingdom adopted a series of new sanctions packages against Russia that are expansive and multilayered and pose additional compliance challenges. The new...more

Torres Trade Law, PLLC

OFAC and BIS Announce Microsoft Settlement of Sanctions and Export Control Violations

Torres Trade Law, PLLC on

On April 6, 2023, the Department of Treasury Office of Foreign Assets Control (“OFAC”) and the Department of Commerce Bureau of Industry and Security (“BIS”) announced a settlement with Microsoft Corporation (“Microsoft”) and...more

The Volkov Law Group

Microsoft’s OFAC Settlement Underscores Important Remedial Measures (Part II of II)

The Volkov Law Group on

Microsoft’s remedial steps provide important best-practices for companies facing similar risk factors in the global economy, especially for global software companies that rely on Internet-based operations....more

The Volkov Law Group

Microsoft Pays OFAC and BIS Over $3.3 Million for Violations of Multiple Sanctions Programs (Part I of II)

The Volkov Law Group on

OFAC announced only one settlement in the first three months of 2023.  Given its ongoing role in the implementation and enforcement of Russia Sanctions, OFAC’s enforcement record so far is completely understandable.  The...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - April 2023 - OFAC Enforcement Trends – Lack of Due Diligence in Mergers and Acquisitions

With roughly 12,000 names now associated with the Specially Designated Nationals and Blocked Persons List (“SDN”), layered sanctions on activities with Russia, and growing sanctions on China activities, U.S. sanctions have...more

Husch Blackwell LLP

OFAC's Crackdown on Tornado Cash Protocol Raises Specter of Future Liability Concerns

Husch Blackwell LLP on

The Office of Foreign Assets Control (OFAC) recently made the unprecedented move of sanctioning a smart contract — a decentralized digital currency mixer called “Tornado Cash” — along with certain cryptocurrency addresses...more

Wiley Rein LLP

Treasury, Commerce Target Russia’s Tech Sector, Defense Industrial Base

Wiley Rein LLP on

On March 31, 2022, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on 21 entities and 13 individuals “as part of its crackdown on the Kremlin’s sanctions evasion networks and...more

Dorsey & Whitney LLP

United States Imposes More Sanctions to Block Russian Access to U.S. Banking System and U.S. Goods, Technology or Software

Dorsey & Whitney LLP on

On February 24, 25 and 28, the United States broadened its economic sanctions against Russia in response to its full-scale military invasion of Ukraine. As the Biden Administration had promised in recent weeks, in close...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & Policy Newsletter - June 2021

1. Recent Enforcement: Even Companies That Invest in Compliance Pay Penalties- Since our April enforcement roundup, the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) in the Department...more

Akin Gump Strauss Hauer & Feld LLP

Reminder Regarding the Jurisdictional Reach and Limits of U.S. Export Control, Sanctions, and Foreign Investment Regulations

United States export control, sanctions, and foreign investment (CFIUS) regulations advance U.S. national security and foreign policy interests, but in very different ways. They are also quite complex. As a result, media...more

The Volkov Law Group

Swiss Telecomm Company Pays $7.8 Million to Settle OFAC Sanctions Violations

The Volkov Law Group on

OFAC continues to aggressively enforce its sanctions programs.  In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an...more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Sanctions/Export Controls Trends in 2020

This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more

Society of Corporate Compliance and Ethics...

Focus on US economic sanctions compliance: OFAC imposes fines and expects more monitoring

Report on Supply Chain Compliance 3, no. 2 (January 23, 2020) - The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), the primary U.S. government agency that administers U.S. economic sanctions, was busy...more

The Volkov Law Group

OFAC Announces Russia Sanctions Settlement with Software Company

The Volkov Law Group on

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced a settlement against Cobham Holdings (and its former subsidiary Aeroflex/Metelics, Inc. (“Metelics”, a software company) for $87,507 for...more

Skadden, Arps, Slate, Meagher & Flom LLP

"OFAC Eases Restrictions on the Export of Medical Devices to Iran"

On December 22, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced amendments to the general license (GL) that authorizes the export or re-export of certain medical devices to Iran....more

BakerHostetler

The Nuclear Deal With Iran: The Lifting of Sanctions and Implications for Business

BakerHostetler on

On July 14, 2015, after two years of sometimes intense negotiations, the United States, the United Kingdom, France, Germany, Russia, and China (known as the “P5+1” countries), along with the European Union, signed a Joint...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Sanctions Relief Under the P5+1 Agreement With Iran: Implications for US, EU and International Business"

Editor’s note: This article was updated on July 23, 2015, to Editor’s note: This article was updated on July 23, 2015, to reflect certain additional information in U.N. Security Council Resolution 2231. On July 14, 2015,...more

Sheppard Mullin Richter & Hampton LLP

New Law Expands Scope of Iran Sanctions In New Ways

As the new year brings in a new term for the Obama Administration, the pace of Iran sanctions shows no sign of slowing. As we reported in October and November, Washington’s commitment to denying Iran the ability to advance...more

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