News & Analysis as of

Sanctions SDN List International Emergency Economic Powers Act (IEEPA)

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

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

Orrick, Herrington & Sutcliffe LLP

Treasury Actions to Counter Ransomware

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several actions focused on disrupting criminal digital finance infrastructure, including virtual currency...more

Morgan Lewis

OFAC Issues Updated Advisory on Sanctions Risks for Facilitating Ransomware Payments

Morgan Lewis on

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” This advisory continues prior advisory...more

Adams & Reese

The Department of Treasury Issues Guidance Regarding Sanctions Risks Inherent to Facilitating Ransomware Payments

Adams & Reese on

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory outlining the risks involved with facilitating ransom payments to malicious actors conducting...more

Morrison & Foerster LLP

OFAC Issues Advisory Highlighting Art Trade No “Goghs”

Morrison & Foerster LLP on

On October 30, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published an advisory highlighting potential sanctions risks arising from dealings in “high-value artwork” (with “particular...more

Foley Hoag LLP

First A Ransomware Attack, Now Sanctions? New OFAC Advisory Warns of Sanctions Risks for Facilitating Ransomware Payments

Foley Hoag LLP on

On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an advisory regarding potential sanctions risks related to facilitating ransomware payments... OFAC is the federal...more

Morrison & Foerster LLP

Cyber Sanctions and National Security

In response to the growing cyber security threats from outside of the United States, the U.S. Government has added an entire new category of sanctioned individuals and organizations to its list of Specially Designated...more

Akerman LLP

Recent Trends in DOJ Investigations Against Major Financial Institutions Involving U.S. Economic Sanctions

Akerman LLP on

With the imposition of billion-dollar fines against large financial institutions, the U.S. Department of Justice ("DOJ") is focusing on banks for not only failing to comply with federal laws, but also for willfully violating...more

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