News & Analysis as of

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

Health Care Compliance Association (HCCA)

Managing Sanctions Compliance

It’s not a good time to be a manufacturer of ten-foot poles. That’s because with the growing number of sanctions regimes, there are an increasing number of companies and individuals that businesses shouldn’t touch with a poll...more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

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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

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more

Seward & Kissel LLP

OFAC Announces Wind Down of Chevron’s Oil Operations in Venezuela

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On March 4, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 41A, “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint...more

K2 Integrity

Escalation Against Cartels: U.S. Designates International Cartels as Foreign Terrorist Organizations and Specially Designated...

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On 20 February 2025, the United States (U.S.) Department of State designated eight international cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The designation of...more

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

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Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

K2 Integrity

2024 in Review: A Year of Expanded Sanctions and Trade Controls and Increased Enforcement Actions

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In 2024, global sanctions and trade controls continued to expand, with the United States (U.S.), European Union (EU), and United Kingdom (UK) leading the charge against actors threatening international security and financial...more

Arnall Golden Gregory LLP

OFAC and KoFIU Sanctions Compliance for Financial Technologies Companies

As financial technologies companies expand operations across borders, understanding the sanctions regimes of both the United States and South Korea becomes essential. The U.S. Treasury Department’s Office of Foreign Assets...more

Seward & Kissel LLP

OFAC Announces Two New Waves of Sanctions Targeting Russia’s Oil Production and Exports, Military-Industrial Base, and Sanctions...

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On January 10 and January 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sweeping sanctions targeting Russia’s oil production and exports, military-industrial base, and other...more

Hogan Lovells

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

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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

Baker Botts L.L.P.

Compliance, Enforcement, and Litigation Risk Considerations from President Trump’s Executive Order on Designating New Foreign...

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On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” The order directs the...more

Guidepost Solutions LLC

Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more

Paul Hastings LLP

Crypto Executive Order: A New Era for Digital Assets

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President Trump’s crypto executive order (the Crypto Executive Order) was a first step in the Trump Administration’s articulation of a policy on promoting the lawful use of blockchain technology. It remains to be seen whether...more

Akin Gump Strauss Hauer & Feld LLP

Designation Of Ansar Allah as a Foreign Terrorist Organization (Trump EO Tracker)

Summary This Order re-designates Ansar Allah (also known as the Houthis) a Foreign Terrorist Organization (“FTO”), to be effective within 45 days. The first Trump Administration had previously designated the Houthis as an FTO...more

The Volkov Law Group

OFAC Settles with Individual for $45,179 for Violations of the Global Magnitsky Act

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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

K&L Gates LLP

New US Sanctions Target Russia’s Energy Sector

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On 10 January 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a package of new sanctions targeting Russia’s energy sector. In an effort to curtail Russia’s oil revenue and ability...more

Kilpatrick

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

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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

Kilpatrick

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

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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

Alston & Bird

OFAC Announces Sanctions Against Chinese-Based Cybersecurity Company

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On January 3, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions on a Chinese-based cybersecurity company, Integrity Technology Group, Inc. (“Integrity Tech”). These sanctions...more

Troutman Pepper Locke

OFAC's Latest General Licenses and FAQs Related to Russian Sanctions

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On December 18, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 1B (Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue...more

The Volkov Law Group

American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and...

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent...more

Adams & Reese

International Compliance Digest – November 2024

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While the incoming administration has blanketed the news cycle with newly threatened tariffs against typical targets like China, and against neighboring allies like Canada and Mexico, the current administration has quietly...more

Venable LLP

OFAC Issues Sanctions Compliance Guidance and Scenarios for U.S. and International Maritime Industry

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On October 31, 2024, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued scenario-based guidance specific to the maritime shipping industry....more

Holland & Knight LLP

OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

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Nearly six months after President Joe Biden signed an executive order (EO) authorizing secondary sanctions against Foreign Financial Institutions (FFIs) conducting or facilitating significant transactions with certain...more

BakerHostetler

Key Sanctions Developments During the First Quarter of 2024

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During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more

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