News & Analysis as of

U.S. Treasury Office of Foreign Assets Control (OFAC) Iran

Paul Hastings LLP

Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments

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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

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – February 2024 Update

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February saw a continuing focus on Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the State Department, sanctioned over 500 individuals and entities – the “largest number...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – October 2023 Update

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October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – July 2023 Update

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July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more

The Volkov Law Group

Commerce, Justice, State and Treasury Issue Unprecedented Joint Advisory Concerning Iranian UAV Procurement Activities

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In a relatively rare move for four (4) Cabinet-level Departments, the U.S. Departments of Commerce, Justice, State and Treasury issued an advisory notice on June 9, 2023,  aimed specifically at reminding industry of their...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – March 2023

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You are reading the March 2023 edition of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. March saw...more

Orrick, Herrington & Sutcliffe LLP

OFAC sanctions “shadow banking” network responsible for moving billions for Iranian regime

On March 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against “39 entities constituting a significant ‘shadow banking’ network,” pursuant to Executive Order 13846. OFAC...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – February 2023

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Russia - Russian National Charged with Supplying U.S. Technology to the Russian and North Korean Governments (DOJ Action) Those involved. Ilya Balakaev, Russian national. Charges and penalties. Conspiracy to...more

Orrick, Herrington & Sutcliffe LLP

OFAC sanctions 9 companies for involvement in Iranian petrochemicals and petroleum

On February 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13846, against six Iran-based petrochemical manufacturers or their subsidiaries, as well...more

Orrick, Herrington & Sutcliffe LLP

OFAC issues and amends Iran-related FAQ

On January 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an Iran-related frequently asked question (FAQ) and amended several other Iran-related FAQs. ...more

K2 Integrity

[Webinar] The Iranian Women’s Movement: Sanctions, Human Rights, and the Targeting of Iran’s Morality Police - October 27th, 12:30...

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The recent woman-led and -inspired demonstrations in Iran following the death of Mahsa Amini at the hands of the country's Morality Police have garnered widespread support both in Iran and around the globe. These protests...more

Bass, Berry & Sims PLC

Russia, Ukraine: Update as of October 3

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The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more

ArentFox Schiff

US Threat Assessment: China and Russia Remain Priority, While Emerging Technology and Global Health Security Gain in Importance

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Last week, the House Permanent Select Committee on Intelligence (HPSCI) and the Senate Select Committee on Intelligence (SSCI) each held a hearing on the US Intelligence Community’s (IC) 2022 Annual Threat Assessment, a...more

Morrison & Foerster LLP

OFAC Year in Review 2021 – Part 1

2021 was a year of transition in the United States and for the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s year, while busy, was far different from 2020, as the Biden Administration’s...more

Morrison & Foerster LLP

Sanctions Legislation Watch: What to Expect from Congress as 2021 Comes to a Close

As we approach year’s end, and the pace of legislative activity ramps up, it remains critical to keep a close eye on the sanctions-related bills currently making their way, at varying speeds, through the U.S. legislative...more

WilmerHale

Treasury Releases Long-Awaited Sanctions Policy Review

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The US Treasury Department has released its 2021 Sanctions Review (the “Review”), which describes the US sanctions framework and the agency’s future sanctions priorities. The Review reflects on the evolution over two decades...more

BCLP

SAP Enforcement Action Underscores Importance of Ensuring Compliance Programs Address Considerations Associated with Business...

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On April 29, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury, and the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce announced settlements with German...more

Vinson & Elkins LLP

Berkshire Hathaway’s $4.1 Million OFAC Settlement Underscores Risks Of Subsidiaries’ Compliance Failures And Benefits Of Voluntary...

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On October 20, 2020, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had reached a $4.1 million settlement with Berkshire Hathaway, Inc., the multinational conglomerate holding company...more

Morrison & Foerster LLP

U.S. “Maximum Pressure” Campaign Expands Isolation Of Iran’s Financial Sector

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On Thursday, October 8, 2020, U.S. Secretary of the Treasury Steven Mnuchin identified the Iranian financial sector as subject to the sectoral sanctions of Executive Order (“E.O.”) 13902, escalating the formidable Trump...more

Bradley Arant Boult Cummings LLP

Facilitating Ransomware Payments Entails Sanctions Risks, OFAC Warns

The Treasury Department’s Office of Foreign Assets Control (OFAC) issued an advisory on October 1, 2020, warning companies that engage with the victims of ransomware attacks that they run the risk of violating U.S. sanctions...more

A&O Shearman

Pennsylvania Manufacturing Company To Pay $824,314 To OFAC After Self-Appointing Two Monitors

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On July 28, 2020, a Pennsylvania-based cookware coating manufacturer (the “Company”) agreed to pay a $824,314 penalty to the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) to settle claims that it...more

Morrison & Foerster LLP

OFAC Issues New FAQs Clarifying Iran Secondary Sanctions

On June 5, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued four new frequently asked questions (“FAQs”) that define key terms used in secondary sanctions added to the Iran sanctions...more

Foley Hoag LLP

Cross-Border Compliance Update: February 2020

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Huawei Charged in Racketeering Conspiracy and Conspiracy to Steal Trade Secrets; Temporary General License Extended – On February 13, 2020, Huawei Technologies Co. Ltd. (Huawei) and two of its U.S. subsidiaries were...more

King & Spalding

Virtual Currency as a Threat to National Security?

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In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more

Orrick, Herrington & Sutcliffe LLP

U.S. Targets Additional Iranian Sectors for Sanctions: Broadly Increasing Exposure for Non-U.S. Companies

With new Iran-related sanctions, the U.S. government is making good on threats to give third-country companies a choice – participate in the U.S. market or participate in the Iranian market. ...more

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