News & Analysis as of

SDN List Office of Foreign Assets Control (OFAC) Enforcement Actions

American Conference Institute (ACI)

Preparing for Latin American Sanctions

President Trump’s “America First Trade Policy” is creating new sanctions compliance risk for financial services institutions and companies in an area that historically has not received as much enforcement attention: drug...more

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

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

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

Kilpatrick

8 Key Takeaways | Part One -- 2024 Roundup: Key Takeaways from U.S. Sanctions Enforcement Actions and 2025 Predictions

Kilpatrick on

Throughout 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control ("OFAC") published 12 enforcement actions regarding alleged sanctions violations by foreign and domestic persons and entities....more

A&O Shearman

Fifth Circuit Limits OFAC Authority Over Certain Cryptocurrency Products

A&O Shearman on

On November 26, 2024, the Fifth Circuit Court of Appeals held that the United States Office of Foreign Assets Control (“OFAC”) exceeded its authority by adding an entity that pools and anonymizes crypto transactions to OFAC’s...more

Ballard Spahr LLP

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

Ballard Spahr LLP on

In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado...more

The Volkov Law Group

OFAC Fines U.S. Person $1 Million for Multiple Violations of Sanctions Regime Against Iran

The Volkov Law Group on

In one of the more notable enforcement actions of 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently imposed a $1,104,408 civil penalty on a U.S. person for 75 separate violations...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

Husch Blackwell LLP

The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and...

Husch Blackwell LLP on

Host Gregg N. Sofer welcomes Husch Blackwell partner Grant Leach to the program to discuss the burgeoning set of requirements and restrictions placed on U.S. businesses in connection with trade law. Gregg and Grant identify...more

Adams & Reese

International Compliance Digest – July 2024

Adams & Reese on

July was a big month for compliance with a handful of reports and recommendations on due diligence and best practices concerning forced labor, export controls, sanctions from DHS, BIS, and OFAC. The below updates also...more

Adams & Reese

International Compliance Digest - June 2024

Adams & Reese on

Sanctions and export controls were the top items of interest in June. On the compliance side, OFAC and the BIS announced new sanctions and export controls on Russia and Belarus. The new measures target individuals and...more

The Volkov Law Group

OFAC Settles First Case in 2024: EFG, a Private Bank, Pays $3.7 Million for Sanctions Violations

The Volkov Law Group on

OFAC is getting ready for a big year.  While managing a comprehensive set of sanctions against the Russian Federation in response to its Invasion of Ukraine, OFAC has demonstrated its ability to maintain aggressive...more

BakerHostetler

Crypto Products Launch; Bitcoin Ordinals Project Sells Out; U.S. EIA to Survey Miners; OFAC and DOJ Announce Crypto Actions;...

BakerHostetler on

New Crypto Indices Launch; Crypto Firms Announce Product Integrations - According to a recent press release, SIX, a major Swiss stock exchange and global financial information provider, has launched new SIX Reference Rate...more

McGuireWoods LLP

Recent Sanctions Enforcement Actions Demonstrate Importance of  Incorporating All Available Data into Screening

McGuireWoods LLP on

For U.S. businesses, sanctions compliance has never been more challenging or more important. The U.S. has responded to Russia’s invasion of Ukraine with a broad range of sanctions targeting the Russian government, its...more

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part I)

Foley & Lardner LLP on

Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more

Nelson Mullins Riley & Scarborough LLP

OFAC Sanctions Two Non-U.S. Firms For Breaching Russia Price Cap Policy

The Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department, in the last few days, imposed the draconian penalty of designating two shipping vessels and their registered owners in the UAE and Turkey as...more

Foley Hoag LLP

Government Shutdown Impact: International Trade

Foley Hoag LLP on

As the standoff in Congress on the budget threatens to shut down vast swaths of the federal government, we write to remind clients about how a federal government shutdown would affect international trade and investment. The...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

Oberheiden P.C.

Ten Strategic Considerations for OFAC Appeals

Oberheiden P.C. on

The Office of Foreign Assets Control (OFAC) has oversight of financial transactions involving U.S. and foreign entities. It exercises this authority in several ways, including (i) through the administration of its various...more

BakerHostetler

NFT Used for Service of Process; Blockchain CO2 Monitoring Solution Launches; IRS Addresses Staking; SEC Enforcement Continues;...

BakerHostetler on

Federal District Court Enters Default Judgment Based on NFT Service of Process - A federal district court judge in Florida entered a $2.2 million default judgment against a defendant on whom the judge previously authorized...more

Kilpatrick

4 Key Takeaways - OFAC Enforcement Actions Thus Far in 2023

Kilpatrick on

Although there were not any published sanctions enforcement actions during the first two months of 2023, since March, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has released information on...more

Oberheiden P.C.

OFAC Enforcement Guidelines: What You Need to Know in 2024

Oberheiden P.C. on

The Office of Foreign Assets Control (OFAC) has played an increasingly important role in the federal government’s national security efforts in recent years. As transactions funding terrorist activities, criminal enterprises,...more

Oberheiden P.C.

The Most Important Thing to Keep in Mind When Looking for an OFAC Sanctions Lawyer

Oberheiden P.C. on

Company executives and stakeholders in charge of making decisions to insulate their business from legal liability by the Office of Foreign Assets Control (OFAC) at the U.S. Department of Treasury have a difficult choice to...more

BakerHostetler

Fintech Firms Launch New Products; Crypto Guidance Published by CFTC, EBA, UAE; OFAC Adds Public Keys to SDN List; CFTC, NY AG...

BakerHostetler on

Crypto Firms Announce New Product Launches in Custody, Stablecoins, Wallets - According to a recent press release, Prometheum Capital has received the first-ever approval from the Financial Industry Regulation Authority...more

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