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Russian Sanctions Update: Five Months into the War in Ukraine

It’s been five months since Russia invaded the Ukraine, and the United States has imposed a succession of increasingly severe economic sanctions on Russia and Belarus. A recent study published by Jeffrey Sonnenfeld, a...more

OFAC Enforcement Action: Double Check Your Screening Tools

Some may dismiss OFAC’s recent announcement last week that it issued a Finding of Violation to MidFirst Bank for violations of the Weapons of Mass Destruction Proliferators sanctions regulations as insignificant because OFAC...more

OFAC’s New §501.604 Reporting Requirement: A Small Change with a Big Impact

On June 21, 2019, OFAC changed its requirements for reporting on blocked or rejected transactions under 31 C.F.R. §501.604.  With little fanfare, the interim rule published in the Federal Register greatly expands the...more

U.S. Entities Engaged in M&A Transactions Beware; OFAC Highlights the “Unique Sanctions Risks” Posed by Foreign Acquisitions

On June 13, 2019, OFAC announced a settlement with Expedia Group, Inc. for violations of the Cuban Assets Control Regulations (“CACR”).  (Available here).  Expedia’s foreign subsidiaries assisted more than 2,200 individuals...more

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