News & Analysis as of

Office of Foreign Assets Control (OFAC) U.S. Treasury

Mayer Brown

Russia/Ukraine Sanctions Update - Month of April 2025

Mayer Brown on

I. U.S. SANCTIONS  - White House Reportedly Considering Lifting Sanctions on Russian Energy Assets: On April 23, Politico reported that the White House is debating lifting sanctions on Russia’s Nord Stream 2 natural gas...more

Bracewell LLP

Post Liberation Day --"Secondary Tariffs" Raise Costs Even Higher for International Actors

Bracewell LLP on

President Trump has used tariffs as a significant point of geopolitical leverage since the beginning of his second term. Indeed, his administration dubbed April 2, 2025 “Liberation Day” in honor of a sweeping set of tariffs...more

K2 Integrity

The Expanding U.S. Economic Statecraft: The Introduction Of “Secondary Tariffs”

K2 Integrity on

On 24 March 2025, President Trump issued Executive Order 14245 authorizing Secretary of State Marco Rubio to impose a 25 percent tariff on all goods imported into the United States from any country that directly or indirectly...more

BakerHostetler

Weekly Blockchain Blog - April 2025

BakerHostetler on

U.S. Financial Services Firms Announce Digital Asset Initiatives - A major U.S. financial services company and operator of global financial exchanges and clearinghouses recently announced an agreement with the issuer of the...more

Paul Hastings LLP

A Whirlwind of Change: The Delisting of Tornado Cash

Paul Hastings LLP on

Over the past several years, as U.S. regulators have grappled with the increasing use of cryptocurrency across a spectrum of legitimate and illegitimate commerce, the U.S. Department of Commerce’s Office of Foreign Assets...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

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

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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

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

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

Troutman Pepper Locke

Financial Transactions Related to Russian Energy Now Prohibited: Expiration of OFAC ‎General License 8L

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On March 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) allowed General License (GL) 8L under the Russian Harmful Foreign Activities Sanctions Regulations to expire. As a result, broad OFAC...more

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more

A&O Shearman

Widening the sanctions net in uncertain times: latest developments in the U.S., EU, and U.K.'s sanctions targeting Russia

A&O Shearman on

In the context of the third anniversary of Russia’s invasion of Ukraine, the U.S., EU, and U.K. continue to implement new measures to stifle Russia’s war efforts. The Biden administration continued to escalate sanctions...more

Troutman Pepper Locke

Latest Sanctions Developments: Venezuela, Russia, and Yemen

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The Trump administration continues to ramp up sanctions on Venezuela and Yemen's Houthis, while sending mixed signals about its intentions with respect to Russia. We provide brief updates on these three areas, following up...more

BakerHostetler

Weekly Blockchain Blog - March 2025 #2

BakerHostetler on

Executive Order Establishes Strategic Bitcoin Reserve, Digital Asset Stockpile - On March 6, President Trump issued an executive order (EO), Establishment of the Strategic Bitcoin Reserve and United States Digital Asset...more

Alston & Bird

Will the Trump Administration Ease Russia Sanctions?

Alston & Bird on

Recent news out of the White House indicates that the Trump Administration is seeking to distance the U.S. from Ukraine as a part of ongoing peace talks with Russia. Reuters is now reporting that the White House has...more

Holland & Knight LLP

OFAC Terminates License Authorizing Certain Petroleum-Related Activities in Venezuela

Holland & Knight LLP on

President Donald Trump announced on Feb. 26, 2025, that he was reversing the authorization granted to Chevron Corp. and its subsidiaries (Chevron) by the Biden Administration as a concession aimed at promoting free elections...more

Seward & Kissel LLP

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

Seward & Kissel LLP on

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

Faegre Drinker Biddle & Reath LLP

Trump Administration’s America First Investment Policy to Bring Changes to CFIUS and Outbound Investment Reviews

Below is a summary of some of the measures identified in the Policy, and some suggestions for what foreign and domestic investors should be considering as this goes into effect....more

Jones Day

Mitigating Risk From the Designation of Cartels as FTOs and SDGTs

Jones Day on

The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more

Baker Botts L.L.P.

U.S. Intensifies Its Drive to Penalize Traders and Shippers of Sanctioned Country Oil

Baker Botts L.L.P. on

In another step to deprive a sanctioned country of revenues from petroleum sales, the U.S. government recently sanctioned more than 30 entities and vessels located around the world for their role in brokering the sale and...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

BakerHostetler

White House Increases Scrutiny on Foreign Investors: Why FOCI Is a Concern for International Businesses

BakerHostetler on

Foreign Ownership, Control, or Influence (FOCI) refers to a situation where a foreign entity has the power to directly or indirectly influence the management or operations of a company. FOCI can result from legal means like...more

White & Case LLP

United States Designates Eight Cartels and Transnational Criminal Organizations

White & Case LLP on

Effective February 20, 2025, the United States Designated Eight Cartels and Transnational Criminal Organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs)....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

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