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OFAC Issues Syria General License and FAQs Easing Sanctions

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

New OFAC FAQs Offer Guidance on Insurers’ OFAC Compliance Obligations

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

Outbound Investment Review: Little Immediate Effect, but More is Coming

The US government’s multibranch effort to implement a new regulatory regime designed to regulate outbound investments based on national security concerns moved forward with the White House’s August 9, 2023 Executive Order, EO...more

OFAC Issues Updated Advisory on Sanctions Risks for Facilitating Ransomware Payments

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” This advisory continues prior advisory...more

New Executive Order Carries Forward, Expands Chinese Military Company Sanctions

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

FinCEN Proposes Crypto Reporting and Recordkeeping Requirements

Recently proposed regulations could present significant compliance burdens for the banks and money service businesses that engage in cryptocurrency transactions with unhosted wallets or wallets held in jurisdictions specified...more

Highlights from CFIUS's New Proposed Regulations Implementing FIRRMA

The Committee on Foreign Investment in the United States (CFIUS) on September 17 released its long-awaited proposed regulations implementing many aspects of the Foreign Investment Risk Review and Modernization Act of 2018...more

Implications for Chinese Investment in the US After Section 301 Report

Section 301 provides the president with broad authority to implement new policies and procedures that could impact reviews of Chinese investment in the United States. The president could rely on the International Emergency...more

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