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Regulatory Oversight Office of Foreign Assets Control (OFAC) Corporate Counsel

Troutman Pepper Locke

Unprecedented "Secondary Tariffs" for Oil Trade With Venezuela

Troutman Pepper Locke on

On April 2 — labeled “Liberation Day” by President Trump — the Trump administration is set to add a new sanctions-like boost to its tariff strategy, with a threat to impose unprecedented “secondary tariffs” of 25% on “all...more

ArentFox Schiff

Navigating the Complexities of Forced Labor Laws: ArentFox Schiff's 2024 Guide for Global Businesses

ArentFox Schiff on

In the last few years, changes to the United States enforcement stance on the forced labor import ban authorized by 19 U.S.C. § 1307 and passage of the Uyghur Forced Labor Prevention Act (UFLPA) have fundamentally changed the...more

Fenwick & West LLP

Guidance for the Virtual Currency Industry; 2021 Sanctions Review Shows Increasing Focus on Digital Transactions

Fenwick & West LLP on

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued tailored sanctions compliance guidance for those operating in the virtual currency industry, including technology...more

Perkins Coie

OFAC Releases New Detailed Guidance for the Digital Currency Industry

Perkins Coie on

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released guidance on sanctions compliance for the digital currency industry, the agency’s most detailed guidance to date on...more

Fenwick & West LLP

OFAC Helps Those Who Help Themselves: How a Ransomware Response Plan Can Help Avoid Sanctions Enforcement for Ransom Payments

Fenwick & West LLP on

Many companies have a “no ransomware payment” stance until faced with a ransomware attack, especially an attack that causes significant business disruption. At that point, the company may reconsider its stance (or at least...more

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