News & Analysis as of

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

Bracewell LLP

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

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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

Paul Hastings LLP

A Whirlwind of Change: The Delisting of Tornado Cash

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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

A&O Shearman

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

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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

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

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

Latham & Watkins LLP

Trump Administration Targets Cartels With First Wave of Terrorism Designations

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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

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

DLA Piper on

Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

Hogan Lovells

U.S. State Department reinstates Cuba Restricted List

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The U.S. Department of State has formally republished the Cuba Restricted List, restoring prohibitions on direct financial transactions with numerous Cuban military, intelligence, and security-linked entities. This move...more

Akin Gump Strauss Hauer & Feld LLP

Imposing Sanctions on the International Criminal Court (Trump EO Tracker)

Order imposes financial sanctions and visa restrictions against International Criminal Court (ICC) officials and their family members who assisted in targeting America and Israel. Within 60 days of the date of this order, the...more

Hogan Lovells

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

Hogan Lovells on

The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...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

Paul Hastings LLP

Crypto Executive Order: A New Era for Digital Assets

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President Trump’s crypto executive order (the Crypto Executive Order) was a first step in the Trump Administration’s articulation of a policy on promoting the lawful use of blockchain technology. It remains to be seen whether...more

Hogan Lovells

The United States and the United Kingdom impose new sanctions against the Russian energy sector

Hogan Lovells on

New U.S. and UK sanctions target Russia’s energy sector and supporting infrastructure. On January 10, 2025, the United States and the United Kingdom imposed additional sanctions against Russia, with a focus on its energy...more

Holland & Knight LLP

Trump Administration Rescinds Certain Actions by the Previous Administration to Ease Cuba Sanctions

Holland & Knight LLP on

Within hours after taking office on Jan. 20, 2025, U.S. President Donald Trump signed an omnibus executive order revoking 78 executive actions by the previous administration, dating back to 2021. Among them, President Trump...more

Akin Gump Strauss Hauer & Feld LLP

Designation Of Ansar Allah as a Foreign Terrorist Organization (Trump EO Tracker)

Summary This Order re-designates Ansar Allah (also known as the Houthis) a Foreign Terrorist Organization (“FTO”), to be effective within 45 days. The first Trump Administration had previously designated the Houthis as an FTO...more

Holland & Knight LLP

OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

Holland & Knight LLP on

Nearly six months after President Joe Biden signed an executive order (EO) authorizing secondary sanctions against Foreign Financial Institutions (FFIs) conducting or facilitating significant transactions with certain...more

BakerHostetler

Key Sanctions Developments During the First Quarter of 2024

BakerHostetler on

During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - April 2024

Ford Motor Company Agrees to $365M Settlement for Attempted Tariff Engineering Ford has agreed to settle the long-standing dispute over the tariff classification of vans imported from 2009 to 2013. At the time, Customs and...more

Morrison & Foerster LLP

OFAC Issues Omnibus Accounts Enforcement Case Involving Russia and Other Sanctions Programs

On March 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its first enforcement case of the year and its first ever involving dealings with a Russian designated for sanctions...more

A&O Shearman

U.S. Government announces new West Bank-related sanctions and designations

A&O Shearman on

On February 1, 2024, President Biden issued an Executive Order imposing certain sanctions on persons determined to be undermining peace, security, and stability in the West Bank. In response to current hostilities and...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – December 2023 Update

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December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more

The Volkov Law Group

New Executive Order Expands Treasury’s Authority to Impose ‘Secondary Sanctions’ on Foreign Financial Institutions Involved in...

The Volkov Law Group on

On December 22, 2023, President Joseph R. Biden, Jr. issued an executive order—”Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities”—that subjects certain foreign financial institutions that...more

Husch Blackwell LLP

Executive Order Imposes New Russia Sanctions for Foreign Financial Institutions and Prohibits Additional Russian Imports

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On December 22, 2023, President Biden issued Executive Order 14114, which amended previous Executive Orders in order to authorize the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) to impose additional...more

Husch Blackwell LLP

Biden Administration Issues Executive Order to Restrict U.S. Investment in Chinese Technology Sectors

Husch Blackwell LLP on

Last week, President Biden issued an Executive Order outlining the long-anticipated proposed restrictions on outbound U.S. investments in entities located in China or otherwise subject to China’s jurisdiction. The Executive...more

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