The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) fined GVA Capital Ltd. $215 million, primarily for violating the Ukraine/Russia-related sanctions regulations, when GVA mistakenly concluded that it...more
On January 2, 2025, the US Department of Defense added a number of entities to its list of “Chinese military companies" (CMC List). While being named to this list, by itself, does not prohibit US businesses from continuing to...more
1/23/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Department of Defense (DOD) ,
Economic Sanctions ,
Export Controls ,
Military End Use ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Supply Chain
The US Office of Foreign Assets Control (OFAC) issued Syria General License 24 (GL 24) authorizing certain transactions with the new Syrian government and easing some transactions related to energy and personal remittances....more
Marking what appears to be a reversal of previous policy, the Office of Foreign Assets Control (OFAC) determined that US persons can, subject to certain limitations, include sanctioned persons as speakers at overseas...more
In a ruling eagerly awaited by the cryptocurrency industry, the US Court of Appeals for the Fifth Circuit held that immutable smart contracts on the Tornado Cash crypto-transaction software protocol are not “property” subject...more
The US Office of Foreign Assets Control recently amended its insurance-related FAQ and issued two new FAQs. This focus on insurance-related guidance comes at the same time as an enforcement action targeting an insurer that...more
OFAC’s new FAQ 1097, issued October 10, warns US investors of the need to block securities held at Russia’s National Settlement Depository (NSD), even if the securities or the issuer is not sanctioned. Even if the security is...more
The US Office of Foreign Assets Control first issued the Syrian Sanctions on April 5, 2005, implementing Executive Order 13338, “Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria.” On...more
The Biden administration suspended certain sanctions on the Government of Venezuela, including some impacting Petróleos de Venezuela S.A. (PdVSA), on October 18, 2023. This significant, albeit currently temporary, change in...more
The US continues to increase economic sanctions on Russia and Belarus. February 27 saw multiple actions expanding sanctions, including restrictions on exports of a large swath of equipment and consumer goods, Office of...more
The United States, in concert with Western allies, has imposed sweeping sanctions on Russia in response to President Vladimir Putin’s action in Ukraine. In addition to a full suite of sanctions administered by the US...more
Based on the evolving military operations of the Russian Federation in Ukraine, the United States has imposed additional sanctions on the Russian Federation, Russian leadership, and various financial institutions and...more
In response to the Russian Federation’s recognition of certain regions of Ukraine as independent states which followed an expansion of nearly 200,000 troops on the Ukrainian border, US President Joseph Biden authorized the...more
The new executive order continues the policy of prohibiting US persons’ transactions in the publicly traded securities of select Chinese companies, but expands the scope to include both Chinese companies that operate or have...more
6/9/2021
/ Biden Administration ,
China ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Instruments ,
Foreign Policy ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Prohibited Transactions ,
Securities Transactions ,
Surveillance
The still evolving US sanctions (as well as the EU and now also separate UK sanctions) continue to challenge Russia-related business. The sanctions frameworks are complex, changing, and, at times, inconsistent as well as...more
3/23/2021
/ Bureau of Industry and Security (BIS) ,
CAATSA ,
Crimea ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Infrastructure ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
UK ,
UK Brexit
The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published final rules on January 15, 2021, implementing the sanctions put in place by Executive Order 13936 (EO 13936) and the Hong Kong Autonomy Act...more
2/1/2021
/ China ,
Economic Sanctions ,
Executive Orders ,
Foreign Entities ,
Foreign Relations ,
General Licenses ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC)
The US Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule on January 15 to implement changes to, and impose new licensing obligations under, the Export Administration Regulations...more
1/28/2021
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
End-Users ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
National Security ,
WMD
The US Secretary of the Treasury announced sanctions this summer on 11 individuals who the Secretary views as being involved in implementing the recently enacted Law of the People’s Republic of China on Safeguarding National...more
Regulators expect companies to investigate actual or potential violations completely and to disclose the nature and scope of those violations completely, in order to obtain credit for their disclosures. Identifying violations...more
President Donald Trump issued Executive Order 13936 on July 14 titled “The President’s Executive Order on Hong Kong Normalization” (the Executive Order or EO 13936). On the same day, the Hong Kong Autonomy Act (HR 7440) was...more
7/29/2020
/ China ,
Economic Sanctions ,
Executive Orders ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Preferential Trade Status ,
Risk Management ,
SDN List ,
Trump Administration
Mexican President Andrés Manuel López Obrador recently announced that Mexico is willing to ship gasoline to Venezuela notwithstanding the threat of US sanctions against such activity. ...more
US persons who have engaged in wind-down or maintenance transactions with EN+ Group, UC Rusal, or JSC EuroSibEnergo (or entities they own or control) pursuant to General License 14E or 16E must report those transactions to...more
The Office of Foreign Assets Control recently designated 7 “oligarchs,” 17 government officials, 13 companies, and one bank, all Russian, as Specially Designated Nationals (SDNs), effectively prohibiting US persons...more
The new sanctions fall within the framework of existing US sanctions against Russia, but have expanded their application by classifying new, prominent individuals and companies as “Specially Designated Nationals.” Given the...more
Under the Act, secondary sanctions must be imposed on any US or non-US person, wherever located, that the US President determines has engaged in a “significant transaction” with any entity named on that list....more