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SDN List National Security International Emergency Economic Powers Act (IEEPA)

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

K2 Integrity on

On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...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

Tornado Cash Whiplash – What’s Next for Sanctions?

Troutman Pepper Locke on

We find ourselves in the midst of a raucous debate among sanctions practitioners about the impact of the Fifth Circuit’s recent decision upholding a challenge against the sanctions the Office of Foreign Assets Control (OFAC)...more

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

Hogan Lovells

Court Rulings Reinforce Limitations on Sweeping Executive Orders Based on IEEPA

Hogan Lovells on

Recent court rulings enjoining enforcement of the Trump Administration’s Executive Order (“EO”) targeting TikTok show signs of curbing the sweeping powers of the International Emergency Economic Powers Act (“IEEPA”), which...more

Jones Day

OFAC Guidance on Ransomware Payments Highlights Sanctions Violations Risk

Jones Day on

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

Neal, Gerber & Eisenberg LLP

Potential Sanctions Risks for Facilitating Ransomware Payments

On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory to highlight the sanctions risks associated with ransomware payments related to malicious cyber-enabled...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

Holland & Hart LLP

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

Holland & Hart LLP on

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

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