News & Analysis as of

U.S. Treasury

Hughes Hubbard & Reed LLP

US Sanctions in a Snap: Developments In Sanctions - October 2025

Hughes Hubbard’s “Sanctions in a Snap” is intended to provide a clear and concise summary of recent developments from the Office of Foreign Assets Control (OFAC). We hope you find it helpful in assessing U.S. economic...more

Troutman Pepper Locke

OCC Comptroller Gould Signals a Multifaceted Push to Reinforce Federal Preemption

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At The Clearing House Annual Conference, Comptroller of the Currency Jonathan Gould outlined an agency-wide strategy to defend and promote federal preemption across the banking system. As reported by Law360, he emphasized...more

ArentFox Schiff

Was It a Bird, Was It a Plane? No, It Was the BIS Affiliates Rule!

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It’s hard not to experience whiplash with export controls recently. A little over a month ago, the Bureau of Industry and Security (BIS) announced the new Affiliates Rule, which took effect immediately on September 29....more

Friling Law

Unblocking OFAC-Sanctioned Assets for Personal Needs and Hardship Circumstances

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I. Introduction: The Human Consequences of Asset Blocking - Economic sanctions enforced by the U.S. Treasury’s Office of Foreign Assets Control (OFAC) are some of the most powerful tools in U.S. foreign policy. When a...more

Holland & Knight LLP

Eyes on Washington: Shutdown Briefing – Day 35

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Welcome to the Eyes on Washington: Shutdown Briefing. During the federal government shutdown, we will be sharing concise, client-focused updates to help you stay informed on key developments, legislative dynamics and...more

McDermott Will & Schulte

US Treasury’s Outbound Investment Security Program: Lessons and Insights

On January 2, 2025, the US Department of the Treasury’s (Treasury) Final Rule implementing the Outbound Investment Security Program (OISP) pursuant to Executive Order 14105 went into effect, under which US Persons are...more

Mayer Brown

Russia/Ukraine Sanctions Update - Month of October 2025

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I. U.S. SANCTIONS - U.S. Department of the Treasury Announces Balkans-Related Designation Removals: On October 29, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the deletion of...more

Friling Law

Selling Property in Iran and Transferring Proceeds to the United States: Comprehensive Legal, Sanctions, and Compliance Guide

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I. Executive Overview - In recent years, many Iranian-Americans have faced growing uncertainty when trying to manage property or financial ties in Iran. One of the most sensitive issues is what happens when someone sells...more

Quarles & Brady LLP

Limited Guidance on “No Tax on Tips” and “No Tax on Overtime” Deductions

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On September 22, 2025, the U.S. Department of the Treasury and the IRS issued proposed regulations for the “No Tax on Tips” deduction passed under the OBBB Act, and on October 23, 2025, Treasury Assistant Secretary for Tax...more

Quarles & Brady LLP

SECURE 2.0 Act Retirement Plan Update: Roth Catch-Up Contributions in 2026

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On September 16, 2025, the U.S. Department of the Treasury and Internal Revenue Service (IRS) issued final regulations implementing the Roth catch-up contribution provisions of the SECURE 2.0 Act of 2022. These provisions...more

Whiteford

Client Alert: GENIUS and CLARITY in Practice: Action Steps for Crypto Compliance

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The next 12 months will separate leaders from laggards in U.S. digital finance. Congress’s passage of the GENIUS Act and rapid advancement of the CLARITY Act signal a turning point for stablecoin issuers, DeFi platforms,...more

Bass, Berry & Sims PLC

UPDATE: BIS Affiliates Rule Suspended for One Year Following U.S.-China

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On October 30, U.S. Treasury Secretary Scott Bessent announced that the U.S. Department of Commerce, Bureau of Industry and Security (BIS) will delay the implementation of the recently announced BIS Affiliates Rule for one...more

Kohrman Jackson & Krantz LLP

The “No Tax on Tips” Rule Under the One Big Beautiful Bill: Key Takeaways for Employers

The One Big Beautiful Bill (OBBB), enacted July 4, 2025, introduces a highly publicized provision exempting certain tips from federal income tax. Framed as relief for service-industry workers, the measure in practice...more

Eversheds Sutherland (US) LLP

Proposed Regulations to Withdraw Look-through Rule for Qualified Investment Entities – Changes Will Facilitate Foreign Investment...

On October 20, 2025, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published proposed regulations (the Proposed Regulations) that would withdraw the domestic corporation look-through rule...more

Troutman Pepper Locke

Taxpayer Favorable Proposed Regulations Would Repeal the “Domestic Corporation Look-Through Rule” for Domestically Controlled...

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On October 20, 2025, the Treasury Department issued proposed regulations (the “2025 Proposed Regulations”) that would remove a controversial rule for determining whether a REIT is “domestically controlled.” The 2025 Proposed...more

Dorsey & Whitney LLP

Trump Escalates Sanctions Against Russia

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On October 22, 2025, President Trump imposed new sanctions targeting Russia’s oil and gas sector in response to a “lack of serious commitment to a peace process to end the war in Ukraine.” This is the first major escalation...more

Wilson Sonsini Goodrich & Rosati

Treasury Secretary Bessent Announces Suspension of 50 Percent “Affiliate” Rule for Entity List, Military End-Users List

During a televised interview today, Treasury Secretary Scott Bessent announced that the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) will suspend implementation of the so-called “Affiliates Rule,” which...more

Orrick, Herrington & Sutcliffe LLP

Congressional letter urges Trump administration to preserve Community Development Financial Institutions Fund

On October 23, more than 100 Republican members of Congress penned a bicameral letter to the Treasury secretary and the director of the Office of Management and Budget (OMB), reaffirming support for the Community Development...more

Holland & Knight LLP

U.S. Sanctions Colombia's President Under Global Illicit Drug Trade Program

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The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 24, 2025, designated the Republic of Colombia's sitting president, Gustavo Francisco Petro Urrego (Petro), pursuant to Executive Order (EO)...more

Holland & Knight LLP

Need a Penny? Too Bad: Legal Implications of the U.S. Penny Shortage

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The U.S. Department of the Treasury's decision to cease minting 1-cent coins has led to a severe shortage in penny circulation that requires businesses to adapt their pricing and payment strategies. As organizations respond...more

Thompson Coburn LLP

57. October 22, 2025 | Trump Administration Blocks Major Russian Oil Firms

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In response to Russia’s unprovoked invasions of Ukraine in March 2014 and February 2022, the Department of Treasury implemented various sanctions on Russian entities....more

Stankie Law

Navigating OFAC Sanctions Risks From North Korean Remote Workers

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With the continued rise in remote work, companies now face a unique vector for potentially significant sanctions risks that continues to catch even the most vigilant companies off guard. This threat comes from the Democratic...more

Pillsbury - Global Trade & Sanctions Law

OFAC Designates Rosneft and Lukoil in Significant Expansion of Sanctions Targeting Russia’s Energy Sector

On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced significant new sanctions for Russia’s energy sector, designating Rosneft Oil Company (Rosneft) and Lukoil OAO...more

Skadden, Arps, Slate, Meagher & Flom LLP

Treasury Proposes Repeal of Controversial Look-Through Rule for Domestically Controlled REITs

On October 21, 2025, the Treasury Department published proposed regulations under the Foreign Investment in Real Property Tax Act (FIRPTA) that would repeal the controversial “look-through” rule adopted in final regulations...more

WilmerHale

FinCEN Clarifies Suspicious Activity Reporting Requirements

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On October 9, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the prudential regulators issued joint guidance clarifying regulatory expectations for suspicious activity reports...more

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