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Biden Administration imposes sweeping sanctions against the Russian Energy Sector days ahead of the Trump Transition

On January 10, 2025, the Biden Administration issued a broad sanctions package targeting the Russian energy sector, 10 days in advance of the transition to the incoming Trump Administration. The new sanctions also added two...more

Treasury releases proposed Outbound Investment Security Program rules

On June 21, 2024, the US Department of the Treasury (Treasury) released proposed new federal regulations (Proposed Rules) that, if implemented, would prohibit or require notification of a broad range of outbound investment...more

Treasury’s 2022 CFIUS Annual Report - Highlights and Observations: Greater scrutiny of national security risk in foreign...

On July 31, 2023, the US Department of the Treasury-led Committee on Foreign Investment in the United States (CFIUS or the Committee) released its annual report for calendar year 2022 (2022 Report), which provides insight...more

OFAC issues further guidance on the implementation of the Price Cap Policy for Russian oil

The Office of Foreign Assets Control (OFAC) of the US Treasury Department has issued its eagerly awaited guidance on the mechanisms of its “maritime services” policy and “price cap exception” for the global transport of...more

Sanctions 2.0: US Treasury Department announces results of sanctions policy review and OFAC releases compliance guidance for the...

The US Department of the Treasury (Treasury) has released the results of its review of economic and financial sanctions first announced in December 2020 by then President-elect Biden (Report). From that review, Treasury has...more

OFAC sanctions virtual currency exchange and updates ransomware advisory

On September 21, 2021, the US Department of the Treasury took actions in response to the increasing prevalence and severity of ransomware attacks in the United States and address the central role that virtual currency and...more

President Biden issues Executive Order modifying, but mostly retaining, the Trump Era Chinese Military Company securities ban 

On June 3, 2021, in one of his first major China-related actions, President Biden issued an Executive Order that amends, but keeps intact the core elements of, previous orders issued by President Trump prohibiting US Persons...more

US Removes COSCO Shipping Arm from OFAC Sanctions List

On January 31, 2020, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury removed sanctions on COSCO Shipping Tanker (Dalian). The delisting may have resulted from US-Chinese...more

US issues sanctions against Petróleos de Venezuela, S.A. (PDVSA) 

Arising out of last week’s announcement by the United States to recognize the opposition government in Venezuela, on Monday the Treasury Department designated Petróleos de Venezuela, S.A. (PdVSA), on the Specially Designated...more

OFAC intends to terminate sanctions on Russian aluminum giant RUSAL

On December 19, 2018, the US Department of the Treasury notified Congress of its intention to terminate sanctions imposed on En+ Group plc (En+), as well as its subsidiaries, United Company RUSAL (Rusal) and JSC EuroSibEnergo...more

When your hardship comes in - Treasury proposes hardship withdrawal regulations

On November 9, 2018, the US Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations addressing statutory changes to the section 401(k) hardship distribution rules, including changes made...more

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