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White & Case LLP

United States Designates Eight Cartels and Transnational Criminal Organizations

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Effective February 20, 2025, the United States Designated Eight Cartels and Transnational Criminal Organizations (TCOs) as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs)....more

Troutman Pepper Locke

US Declares War on Cartels: Historic Terrorist Designations Reshape Sanctions Compliance Risks

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On February 20, 2025, the U.S. Departments of State and the Treasury designated eight Latin American drug trafficking cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), in...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

Troutman Pepper Locke

OFAC's Latest General Licenses and FAQs Related to Russian Sanctions

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On December 18, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 1B (Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue...more

Foodman CPAs & Advisors

BIS New Guidance for FI’s Best Practices

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On 10/9/24, the Bureau of Industry and Security (BIS) within the Department of Commerce has issued guidance aimed at financial institutions (FIs), outlining best practices for adherence to the Export Administration...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

King & Spalding

The U.S. Departments of Commerce and State Issue Proposed Rules Expanding Controls on Military and Security-Related Services, End...

King & Spalding on

To curtail U.S. persons from supporting the efforts of adversarial regimes, such as China and Russia, in advancing their military and intelligence capabilities, the U.S. is proposing a significant expansion of export control...more

Latham & Watkins LLP

US Treasury Department Issues Notice of Proposed Rulemaking on Implementation of Outbound Investment: 5 Key Takeaways

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The proposed regulations would implement President Biden’s Executive Order that restricts certain outbound investments from the US. On June 21, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

Dorsey & Whitney LLP

Fundamental Research & National Security: Recent Developments & New Issues

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According to the National Center for Science and Engineering Statistics (“NCSES”), a key driver in the scientific and technological accomplishments of U.S. research universities is the volume of federal support for research...more

Latham & Watkins LLP

OFAC Sanctions Decentralized Virtual Currency Mixer

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The US Treasury opens a Pandora’s box of legal issues as it targets a decentralized finance protocol used for both licit and illicit means. On August 8, 2022, the US Department of the Treasury’s Office of Foreign Assets...more

Hogan Lovells

Foreign commercial activities in Russia: Analyze risks and consider consequences now

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For those enterprises that have or had ongoing business arrangements and investments in Russia, now is the time to assess and fully understand risks entailed –whether electing to stay in Russia, to withdraw, or to curtail...more

Jenner & Block

Escalating Multilateral Sanctions Increase Pressure on Putin’s Support Base

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In the nearly three weeks since Russia’s invasion of Ukraine, over 30 countries continue to increase their sanctions targeting Russian individuals, financial institutions, exports of technology, and key sectors of the Russian...more

Wiley Rein LLP

Biden Administration Sanctions Donetsk, Luhansk Regions of Ukraine

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On February 21, 2022, President Joe Biden issued an Executive Order (EO) in response to Russian President Vladimir Putin’s ongoing “efforts to undermine the sovereignty and territorial integrity of Ukraine.” Referencing a...more

Akin Gump Strauss Hauer & Feld LLP

Ukraine-Russia Crisis: Possible New Sanctions and Export Controls on Russia and Potential Implications for U.S. and Non-U.S....

Key Points - The United States, European Union, United Kingdom and other U.S. allies are currently considering a range of severe economic measures against Russia to impose in the event of a Russian military incursion into...more

Morrison & Foerster LLP

Biden Administration Issues Sweeping New Sanctions On Russia In Response To Election Interference, Malicious Cyber Activity, And...

On April 15, 2021, following discussions just days earlier of a potential summit between President Biden and Russian President Putin and as Russian troops amassed along the Ukrainian border, the Biden Administration issued...more

Jones Day

OFAC Guidance on Ransomware Payments Highlights Sanctions Violations Risk

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The Situation: In an October 1, 2020, Advisory, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") warned that companies that make or facilitate ransomware payments to threat actors who are...more

Bilzin Sumberg

OFAC Issues Regulatory Advisory Warning Against Facilitating Ransomware Payments

Bilzin Sumberg on

On October 1, 2020, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an “Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” The Advisory, which does not carry the...more

Akin Gump Strauss Hauer & Feld LLP

Reminder Regarding the Jurisdictional Reach and Limits of U.S. Export Control, Sanctions, and Foreign Investment Regulations

United States export control, sanctions, and foreign investment (CFIUS) regulations advance U.S. national security and foreign policy interests, but in very different ways. They are also quite complex. As a result, media...more

Ballard Spahr LLP

28 North Korean and 5 Chinese Bankers Accused of a $2.5 Billion Laundering Scheme

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Indictment Again Highlights the Role of Correspondent Banking in Money Laundering - On May 28, 2020, the U.S. Department of Justice (“DOJ”) unsealed a 50-page indictment against 28 North Korean and 5 Chinese bankers...more

Eversheds Sutherland (US) LLP

Update on recent US sanctions developments - Nord Stream 2 sanctions and Exxon Mobil decision

This briefing is intended to provide an update on two recent developments under the US sanctions regime. ..The first one is the introduction of US sanctions related to the Nord Stream 2 pipeline project, which threaten to...more

Porter Hedges LLP

Alert: "The Treasury Department Issues A Framework For OFAC Compliance"

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Earlier this year, the U.S. Department of the Treasury issued a new “Framework for OFAC Compliance Commitments” (the “Framework”). The Office of Foreign Asset Control (“OFAC”) is the Treasury Department’s arm that administers...more

Holland & Hart LLP

OFAC Redefines the Term “Significant Transnational Criminal Organization,” Broadening Its Reach

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has implemented the President’s prior revision of the definition of “significant transnational criminal organization” (significant TCO) by...more

Morrison & Foerster LLP

Not Quite Cuba (Yet): OFAC Blocks The Venezuelan Government’s Property

Hot on the heels of the “Saturday Surprise,” the Trump Administration initiated “Monday Madness” earlier this week when the President issued new Executive Order (E.O.) 13884 blocking any property and interests in property of...more

Akin Gump Strauss Hauer & Feld LLP

Podcast: Venezuela – The Roots and Future of U.S. Sanctions

In this episode, Akin Gump public law and policy senior advisor and former U.S. Rep. Ileana Ros-Lehtinen and international trade partner Nnedi Ifudu discuss U.S. sanctions on Venezuela. Among the topics covered: • the...more

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