On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more
Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more
New developments in international trade laws will have tangible and far-reaching impacts on transactions as well as day-to-day business operations. President Biden’s signing of HR 815 means that once time-barred historic...more
Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities - SUMMARY - On April 24, 2024, President Biden signed into law a foreign military...more
President Biden recently signed a foreign aid bill that will have significant implications for United States sanctions enforcement, specifically Section 206 of the International Emergency Economic Powers Act (50 U.S.C. 1705)...more
Companies around the world have been scrambling to understand the implications of the sanctions imposed by the United States following Russia’s invasion of Ukraine. Beyond sanctions, the United States has even more legal and...more
Recent ransomware attacks against U.S. critical infrastructure, which includes the energy sector’s production of oil and natural gas, and other sources of electricity and power, have shed a spotlight on the importance of...more
On October 1, 2020, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory regarding the potential sanctions risk for entities that facilitate ransomware payments. OFAC defined “ransomware” as: A form...more
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
Fraud and corruption thrive in chaos. The COVID-19 pandemic and its economic destabilization create the conditions in which misconduct can thrive....more
Apollo Settles Alleged Sanctions Violations: Aircraft Lessors Pay Attention - The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has broad delegated authority to administer and enforce the...more
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has broad delegated authority to administer and enforce the sanctions laws and related sanctions programs of the United States. As a key...more
Last December, President Barack Obama announced a series of changes to the United States’ policy toward Cuba. The most significant changes, from a foreign policy perspective, included restoring diplomatic relations with Cuba...more
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