News & Analysis as of

Sanctions Office of Foreign Assets Control (OFAC)

WilmerHale

Implications of EO 14157 and Recent “Foreign Terrorist Organization” and “Specially Designated Global Terrorist” Designations

WilmerHale on

On January 20, 2025, President Donald J. Trump signed Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists” (EO 14157)....more

Foley & Lardner LLP

The Non-Compliant Cat in the Hat

Foley & Lardner LLP on

So, just before Easter, in 1957, a little book you may have heard of, called The Cat in the Hat, made its first appearance. Theodore Geisel — writing under the name “Dr. Suess” — later said that of all his children’s books,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Understanding and Mitigating Legal and Compliance Risks Relating to Cartels and Transnational Criminal Organizations

On his first day in office, President Trump signed Executive Order 14157 calling for the designation of certain cartels and transnational criminal organizations (TCOs) as foreign terrorist organizations (FTOs) or specially...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

StoneTurn

Do You Know Who Your Employee Is? Mitigating DPRK IT Worker Risk

StoneTurn on

North Korean IT operatives are infiltrating U.S. and Western companies using stolen or fabricated identities, VPNs, and U.S.-based co-conspirators to gain unauthorized access to corporate systems. These insider threats pose...more

Seward & Kissel LLP

President Trump Seeks “Maximum Pressure” on Iran Through Expansion of Sanctions Targeting Iran’s Oil Exports

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As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...more

Woods Rogers

Designating Cartels as Terrorists: Potential Impact on U.S. Businesses

Woods Rogers on

On his first day in office, President Trump signed an executive order (EO 14157) that sets in motion the designation of certain cartels and transnational crime gangs as terrorist organizations. The President declared a...more

Guidepost Solutions LLC

Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...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

J.S. Held

Engaging With Chinese Companies: Managing ‘Proxy Sanctions’ Risk

J.S. Held on

We are entering a year of acute political risk for international trade, with a high likelihood that the Trump administration will hit China with punitive tariffs and increased export controls. Against the backdrop of trade...more

The Volkov Law Group

OFAC Settles with Individual for $45,179 for Violations of the Global Magnitsky Act

The Volkov Law Group on

OFAC means what it says — in more ways than one.  In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations....more

Pillsbury - Global Trade & Sanctions Law

Framework for Collaboration Between U.S. and UK Sanctions Authorities

Earlier this week, the U.S. Office of Foreign Assets Control (OFAC) and the UK Office of Financial Sanctions Implementation (OFSI) published a Memorandum of Understanding (MoU), which was previously signed on October 9, 2024,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Political Changes Are Unlikely To Fundamentally Alter Key Sanctions

Key Points - - Political transitions in the West notwithstanding, we expect economic sanctions to remain a key response to geopolitical issues. - Current sanctions policy priorities are unlikely to shift markedly in...more

Venable LLP

Outgoing Administration Issues Sweeping Russia Energy Sector Sanctions

Venable LLP on

On January 10, 2025, the US government issued the latest round of sanctions targeting Russia’s revenue sources used to fund its war in Ukraine....more

Morgan Lewis

OFAC Issues Syria General License and FAQs Easing Sanctions

Morgan Lewis on

The US Office of Foreign Assets Control (OFAC) issued Syria General License 24 (GL 24) authorizing certain transactions with the new Syrian government and easing some transactions related to energy and personal remittances....more

Katten Muchin Rosenman LLP

OFAC Sanctions Russia's Energy Sector

In an effort to reduce Russian energy revenues being used to fund the war against Ukraine, on January 10, 2025, the United States Department of the Treasury's Office of Foreign Assets Control (OFAC), issued a “determination”...more

Bracewell LLP

Biden Administration Issues Sweeping Salvo of Sanctions Against the Russian Energy Sector

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On January 10, 2025, in a final action to, among other things, deter Russian aggression on the international stage, the US Department of the Treasury enacted sweeping new sanctions on the Russian energy sector. Specifically,...more

Alston & Bird

OFAC Announces Sanctions Against Chinese-Based Cybersecurity Company

Alston & Bird on

On January 3, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions on a Chinese-based cybersecurity company, Integrity Technology Group, Inc. (“Integrity Tech”). These sanctions...more

Ropes & Gray LLP

Russia/Ukraine Crisis: U.S. Targets Russia’s Energy Industry

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On January 10, 2025, the United States announced (another) major sanctions package targeting Russia, potentially representing the Biden administration’s last and best effort to strengthen Ukraine’s negotiating position in...more

ArentFox Schiff

OFAC Relaxes Sanctions Against Post-Assad Syria – For Now

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The US government signals careful optimism with a new general license authorizing some previously prohibited transactions, including many (but not all) transactions with Syrian governing institutions, for the next six months....more

Conyers

Navigating International Sanctions: Impact of the Ukraine War on Bermuda

Conyers on

When Russia invaded Ukraine on 22 February 2022 most Bermudian residents did not think it would have much impact to the island. However as both an overseas territory of the United Kingdom and as an international finance...more

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - November 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

Bass, Berry & Sims PLC

German Company Pays $14.55 Million to Settle Violations of U.S. Sanctions on Iran

Bass, Berry & Sims PLC on

Key Points: - Long-arm of U.S. sanctions jurisdiction reaches conduct by European company. - Violation involved shipment to Iran from Australia, a close U.S. ally. On December 3, the Treasury Department’s Office of...more

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Overturns OFAC Sanctions on Blockchain-based Privacy Technology

On November 26, the U.S. Fifth Circuit Court of Appeals overturned sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) against a decentralized cryptocurrency mixing service (a...more

Foley Hoag LLP

OFAC Publishes Updated Maritime Oil Industry Advisory

Foley Hoag LLP on

On October 21, 2024, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) issued an Updated Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors (“Updated Advisory”). OFAC...more

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