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Acquirors Beware: PE Firm Escapes DOJ Prosecution, but Acquired Entity Hit With $2 million+ in Penalties

In March 2024, NSD issued an updated Enforcement Policy for Business Organizations (NSD Enforcement Policy) that includes the M&A Policy.  Under the M&A Policy, where an acquiring company makes a qualifying voluntary...more

Trump Administration Issues Sweeping Sanctions Relief for Syria

On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25 to provide immediate sanctions relief for Syria in line with President Trump’s May 13, 2025...more

OFAC Reimposes Venezuela Oil and Gas Sector Sanctions but Leaves Door Open for Possible Specific Licensing

Key Points - On April 17, 2024, based on a determination by the U.S. government that Nicolás Maduro and his representatives “have not fully met the commitments made” with respect to upcoming Venezuelan elections, the U.S....more

OFAC Issues Venezuela Sanctions Relief Package Focused on Oil, Gas and Gold Sectors and Secondary Market Trading in Response to...

Key Points - On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took action to relax certain U.S. sanctions on Venezuela in response to the signing of an electoral roadmap...more

2022 Economic Sanctions Year in Review and Outlook for 2023

Introduction - In 2022, the United States, European Union (EU) and United Kingdom, along with a significant number of other partners and allies, imposed an unprecedented number of economic, financial and trade sanctions...more

New Requirements for UAE Companies Under Updated Targeted Financial Sanctions Guidance

Through updated guidance, the UAE has introduced a significant change to how it administers sanctions regimes—expanding its focus from a limited implementation of multilateral sanctions to more broadly imposing its own...more

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