On June 30, 2025, the President signed an Executive Order (EO) lifting sanctions on Syria and directing the U.S. Department of State (DOS) and the U.S. Department of Commerce (DOC) to relax or suspend other programs (e.g.,...more
The Singapore Exchange (SGX) expects issuers to manage global sanctions risk, not just the risk from Singapore-imposed sanctions. Sanctions risks need to managed on a group-wide basis, including subsidiaries and affiliates...more
General License (GL) 25 authorizes transactions previously prohibited by various regulations. Specifically, Section (a) broadly authorizes activities previously prohibited under the Office of Foreign Asset Control (OFAC)’s...more
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
New U.S. and UK sanctions target Russia’s energy sector and supporting infrastructure. On January 10, 2025, the United States and the United Kingdom imposed additional sanctions against Russia, with a focus on its energy...more
The Fifth Circuit held that Tornado Cash, open-source computer code known as an immutable “smart contract”, is not “property” and thus cannot be subject to blocking sanctions pursuant to IEEPA and EO 13694....more
The Office of Foreign Assets Control of the US Department of Treasury imposed sanctions against three private entities and one individual for assisting in the development and production of Russia’s Garpiya series long-range...more
On 12 June 2024, the US Departments of Treasury, State, and Commerce imposed new restrictions targeting Russia, including: (i) restricting the provision of certain information technology and software services to Russia...more
The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an interim final rule set to take effect August 8, 2024, which amends the Reporting, Procedures, and Penalties Regulations (the “Regulations”)...more
Congress has doubled the statute of limitations for violations of most U.S. sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control. Companies should be aware of the...more
October 2023 marked the first anniversary of the enhanced partnership between the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the United Kingdom Office of Financial Sanctions...more
Following the death of political activist Aleksey Navalny and to mark the second anniversary of Russia’s invasion of Ukraine, the United States, EU and UK adopted a series of amendments to their respective economic sanctions...more
On December 22, 2023, President Biden issued a new Russia-related Executive Order (“EO”) targeting foreign financial institutions (“FFIs”) that support Russia’s military-industrial base. The new EO allows the U.S. government...more
In recognition of political progress between the Government of Venezuela and opposition parties—notably, the signing of an electoral roadmap agreement between the Unitary Platform and representatives of Nicolas Maduro--the...more
On May 19, 2023, the US Department of Treasury, State, and Commerce imposed the most significant tranche of sanctions and export control measures in several months. The measures included (i) new designations on the Specially...more
On 2 December 2022, the US Department of the Treasury issued a press release announcing a $60/barrel price cap that will apply to the prohibition on US persons from engaging in a broad range of services related to the...more
On 9 September 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published “Preliminary Guidance on Implementation of a Maritime Services Policy and Related Price Exception for Seaborne...more
The U.S. Government has imposed additional punitive measures against Russia in response to Russia’s actions in Ukraine. The new measures include a prohibition on imports of Russian gold into the United States, new SDN and...more
7/5/2022
/ Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Supply Chain ,
Ukraine
The Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) No. 22 on May 12, 2022, authorizing transactions that are ordinarily incident and necessary to activities that occur in specified, non-regime held...more
On February 24, 2022, the US Government imposed severe economic sanctions and export controls on Russia. The restrictions consist of two parts: 1) significant financial sanctions on a range of Russian financial institutions...more
The Court of Justice of the EU has interpreted for the first time the Blocking Regulation. The ruling confirms that it is possible to terminate contracts with a US designated person without providing reasons. However, in...more
The decision to pay millions to a cyber criminal has never been easy, but it is now even more complex. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory on September 21,...more
On 15 April 2021, the U.S. Government announced a number of new sanctions measures against Russia, targeting a variety of “harmful foreign activities” contrary to U.S. foreign policy. ...more
4/21/2021
/ Biden Administration ,
Crimea ,
Critical Infrastructure Sectors ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts
The Cuban Assets Control Regulations have been amended to prohibit U.S. persons from lodging at certain properties in Cuba, incorporate restrictions on imports of Cuban alcohol and tobacco, and revoke general licenses...more
On 24 September 2020, the U.S. Department of Treasury's Office of Foreign Asset Control (OFAC) announced a settlement with Keysight Technologies, Inc. (Keysight) for sanctions violations committed by its former subsidiary,...more
10/7/2020
/ Corruption ,
Country of Origin ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
General Licenses ,
Goods or Services ,
Iran Sanctions ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations