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
As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...more
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
On November 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took further action to restrict Russia’s access to the international financial system by designating Gazprombank Joint Stock...more
Each year, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) requires all holders of blocked property to submit an Annual Report of Blocked Property (“ARBP”) setting forth all blocked...more
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
7/26/2024
/ Compliance ,
Economic Sanctions ,
Financial Services Industry ,
Foreign Policy ,
Interim Final Rules (IFR) ,
International Emergency Economic Powers Act (IEEPA) ,
Liquidation ,
National Security ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Reporting Requirements ,
Russia ,
TWEA ,
Ukraine
On June 12, 2024, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), in coordination with the U.S. Department of State, announced a new wave of Russia sanctions that significantly expand...more
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
On February 8, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the imposition of sanctions against a network of foreign entities and a vessel involved in an asserted price cap...more
The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more
1/26/2024
/ AML/CFT ,
Audits ,
Civil Monetary Penalty ,
Compliance ,
Criminal Penalties ,
Crude Oil ,
Cryptocurrency ,
Due Diligence ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
International Emergency Economic Powers Act (IEEPA) ,
Liability ,
Maritime Transport ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Risk Assessment ,
Sanction Violations
On January 18, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the imposition of sanctions against a United Arab Emirates-based shipping company, Hennesea Holdings Limited (“Hennesea”)...more
On December 12, 2023, the Department of Justice (DOJ), Department of Commerce’s Bureau of Industry and Security (BIS), Department of Homeland Security’s Homeland Security Investigations (HSI), the Department of State’s...more
On December 1, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets control (OFAC) announced the imposition of sanctions on three entities and identified as blocked property three vessels that used Price Cap...more
On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) eased certain sanctions on the oil and gas sector, as well as the gold sector, in Venezuela, following the announcement of a...more
On October 12, 2023, OFAC released an Advisory for the Maritime Oil Industry and Related Sectors: Best Practices in Response to Recent Developments in the Maritime Oil Trade on behalf of the G7, European Union and Australia...more
The ascending importance of rigorous and compliance with U.S. national security laws, including sanctions and export controls, was underscored on July 26, 2023 with the release of a Department of Commerce, Department of the...more
8/2/2023
/ Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Export Controls ,
FinCEN ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements
On May 19, 2023 the United States, in coordination with the G7 and other international partners, imposed more than three-hundred new sanctions on Russia for its war in Ukraine. Press releases providing additional information...more
On April 17, 2023, the United States Treasury Department’s Office of Foreign Assets Control (OFAC) issued an alert warning U.S. persons about possible evasion of the price cap on Russian Federation origin crude oil,...more
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
As noted in our prior alerts (concerning OFAC’s September 9, 2022 preliminary guidance, an October 31, 2022 follow-on FAQ clarifying the applicability of the price cap policy, and the December 5, 2022 effective date of the...more
On December 20, 2022, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it was amending its regulations in multiple sanctions programs to reflect that the property and interests in property...more
As noted in our prior alerts (concerning OFAC’s September 9, 2022 preliminary guidance and October 31, 2022 follow-on FAQ clarifying the applicability of the impending price cap policy) the U.S. Department of the Treasury’s...more
On October 31, 2022 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published FAQ 1094, which addresses the question of whether crude oil of Russian Federation origin that is loaded onto a vessel...more
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
The United States sanctions regime is a complex and ever-changing regulatory space. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) maintains sanctions lists which are updated in real-time—not on...more