News & Analysis as of

Sanctions

Paul Hastings LLP

Potential US Designation of Brazilian Criminal Networks as Terrorist Organizations: Compliance Risks for Companies

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Brazilian and other multinational companies with operations in Latin America can no longer be focused exclusively on exposure to Mexican cartels when considering the risks associated with foreign terrorist organizations...more

Stevens & Lee

AI Hallucination Reaches the Third Circuit

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We previously commented on the scourge of non-existent legal decisions hallucinated by generative artificial intelligence databases finding their way into lawyers’ case filings. Our earlier piece discussed a Pennsylvania...more

Morrison & Foerster LLP

Treasury Proposes New AML/CFT and Sanctions Obligations for Payment Stablecoin Issuers Under the GENIUS Act

On April 8, 2026, the U.S. Department of the Treasury issued a joint notice of proposed rulemaking (the NPRM or Proposed Rule) through the Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control...more

Wilson Sonsini Goodrich & Rosati

North Korea-Linked Schemes to Obtain Employment in U.S. Tech Companies: What You Need to Know and How to Respond

During the past few years, operatives associated with the Democratic People’s Republic of Korea (North Korea or the DPRK) have reportedly infiltrated hundreds of U.S. companies by fraudulently posing as legitimate remote IT...more

Paul Hastings LLP

Caught in the Cartel Crossfire: Rising US Corporate Enforcement Risks for Companies and Financial Institutions

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On April 29, in a remarkable escalation in the United States’ war against drug cartels, the U.S. Department of Justice (DOJ) charged the sitting governor of the Mexican state of Sinaloa, along with other current and former...more

Hogan Lovells

China’s new regulations complicate compliance landscape for multinationals

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China's State Council (the “State Council”) recently issued two State Council administrative regulations that expand the compliance dimensions multinationals shall navigate when operating in China alongside foreign sanctions,...more

Haynes Boone

SALEFORM 2025: A Modern Rewrite for Vessel Deals in a New Global Reality

Haynes Boone on

The Norwegian Shipbrokers’ Association and BIMCO recently adopted SALEFORM 2025, a new standard form memorandum of agreement (MOA) for the sale and purchase of vessels. The new standard form introduces welcome updates to...more

Paul Hastings LLP

New US Sanctions Against Cuba Expand Sanctions Risks for Global Multinationals

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In a move that signals a fundamental change in the U.S. regulatory and enforcement risk calculus for multinational companies and financial institutions that operate in or facilitate transactions with the Cuban economy, the...more

Troutman Pepper Locke

GENIUS Act AML and Sanctions Rules for Stablecoin Issuers: A Few Surprises but Broadly as Expected

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On April 10, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) jointly issued a notice of proposed rulemaking (NPRM) setting out their view of how sanctions,...more

Ballard Spahr LLP

Treasury’s Proposed Rule Brings Stablecoin Issuers into the BSA Framework

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On April 8, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) issued a joint Notice of Proposed Rulemaking (NPRM) to implement the Guiding...more

Skadden, Arps, Slate, Meagher & Flom LLP

EU Adopts 20th Russia Sanctions Package

On 23 April 2026, the European Union adopted its 20th package of sanctions against Russia and Belarus, further amending Council Regulation (EU) No 833/2014 (Regulation 833), Council Regulation (EU) No 269/2014 (Regulation...more

Morgan Lewis

EU Adopts 20th Sanctions Package Against Russia, Expands Anti-Circumvention Efforts

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The European Council (the Council) recently adopted the 20th economic sanctions package against Russia in response to the conflict in Ukraine (the 20th Package). The 20th Package introduces a broad set of new restrictive...more

Hogan Lovells

FATF publishes Mutual Evaluation Report on Italy

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The Financial Action Task Force (FATF) has published its Mutual Evaluation Report (MER) on Italy, assessing the effectiveness and technical compliance of the Italian framework to combat money laundering and terrorist and...more

A&O Shearman

Conflict response managing the operational and supply chain impact of military action

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Against a backdrop of rising military conflict across the world, people, assets and supply chains are at risk. Here we explore the business impact of the war in the Middle East, although the general points are applicable...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Introduces Sanctions End-Use Controls

On 22 April 2026, the UK government laid before Parliament the Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2026 (Regulations), a statutory instrument which makes a number of changes to the UK’s sanctions...more

Akin Gump Strauss Hauer & Feld LLP

Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign...

Expands upon Executive Order 14380 that established a national emergency regarding Cuba due its threat to U.S. national security by directing the Department of State and Treasury to block U.S. trade with foreign persons...more

Baker Botts L.L.P.

The Law of War - Force Majeure in Time of War (and Peace)

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The events in the Gulf region have affected the supply of gas and natural gas and petroleum, but also aluminum (together the “products”) considering the number of refineries in the region....more

Hogan Lovells

Strait of Hormuz disruption – Disputes risks for energy and infrastructure projects

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The Strait of Hormuz is one of the world's most critical maritime chokepoints, carrying roughly 25% of global seaborne oil trade – around 20 million barrels per day. Its stability underpins global energy supply and the...more

DLA Piper

LNG disputes emerge after disruption at Ras Laffan, Strait of Hormuz: Key considerations

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Industry sources estimate that in 2025, more than 80 million tons of liquefied natural gas (LNG) transited the Strait of Hormuz, the vast majority originating from Qatar's Ras Laffan complex. Recent events at Qatar's Ras...more

Blank Rome LLP

MAINBRACE: April 2026

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I recently had coffee with an acquaintance who works in real estate. He was aware that our law practice has a focus on shipping and presumed we were very busy because of the events taking place in the Strait of Hormuz. What...more

Blank Rome LLP

The BR Investigations and Enforcement Forum: April 2026

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Welcome to The BR Investigations and Enforcement Forum (“B.R.I.E.F.”), Blank Rome’s monthly newsletter highlighting enforcement priorities and compliance risk issues impacting businesses domestically and abroad. B.R.I.E.F....more

Orrick, Herrington & Sutcliffe LLP

FinCEN and OFAC Propose Rule for Payment Stablecoin Issuers to Implement GENIUS Act

Payment stablecoin issuers would face comprehensive new AML/CFT and sanctions compliance obligations under a joint proposed rule issued April 8, 2026, by the Department of the Treasury’s Financial Crimes Enforcement Network...more

Davies Ward Phillips & Vineberg LLP

The Creation of Canada’s Financial Crimes Agency: A New Era in Financial Crime Enforcement

The Government of Canada introduced Bill C-29, An Act to establish the Financial Crimes Agency and to make consequential amendments to certain Acts and regulations (Bill), on April 27, 2026. This Bill will establish the...more

Mayer Brown

UK Weekly Sanctions Update - Week of April 20, 2026

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In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London...more

K&L Gates LLP

UK Government's Strategic Approach to Sanctions Enforcement

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On 29 January 2026, HM Treasury’s Office of Financial Sanctions Implementation (OFSI) published its response to the consultation on improving civil enforcement of financial sanctions, followed by updated enforcement and...more

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