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Compliance Flash: OFAC Announces New Reporting Requirement for Financial Institutions Under the REPO for Ukrainians Act

The supplemental appropriations legislation signed into law on April 24, 2024 enacted numerous high-profile provisions addressing aspects of U.S. foreign policy and national security, including provisions that broaden and...more

Full Steam Ahead on Russia Sanctions

2024 has already been a busy year for sanctions on Russia, with the implementation of new sanctions and intensifying enforcement of existing sanctions authorities, with no signs of slowing down....more

OFAC Expands Russia Sanctions and Issues New General Licenses

On February 24, 2023, the one-year anniversary of Russia’s invasion of Ukraine, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the imposition of additional sanctions targeting multiple...more

Economic Sanctions and the Russian Oil Price Cap Policy

Background - As the Russia-Ukraine war approaches its one-year anniversary with no end in sight, U.S., EU and UK authorities, among other nations, continue to exert calculated but sustained pressure on the Russian...more

OFAC Issues Preliminary Guidance on Implementation of Maritime Services Policy and Related Price Exception for Seaborne Russian...

On September 9, 2022 OFAC issued a preliminary guidance on the Implementation of a Maritime Services Policy and Related Price Exception for Seaborne Russian Oil in furtherance of a policy established by a coalition of...more

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