President Trump has used tariffs as a significant point of geopolitical leverage since the beginning of his second term. Indeed, his administration dubbed April 2, 2025 “Liberation Day” in honor of a sweeping set of tariffs...more
4/9/2025
/ China ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Human Rights ,
Imports ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Tariffs ,
Trump Administration ,
U.S. Treasury ,
Venezuela
As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more
4/3/2025
/ Anti-Money Laundering ,
Cartels ,
Civil Liability ,
Criminal Liability ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Financial Institutions ,
International Emergency Economic Powers Act (IEEPA) ,
Mexico ,
Money Laundering ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Terrorist Organizations ,
Trump Administration
The US State Department has made its first round of designations pursuant to Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists,”...more
2/27/2025
/ Anti-Corruption ,
Corporate Counsel ,
Criminal Prosecution ,
Economic Sanctions ,
Executive Orders ,
Foreign Entities ,
Foreign Investment ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Risk Management ,
Terrorism Funding
Shortly after President Trump’s second inauguration, his executive branch took steps to further one of his signature promises: securing the southern border. While these actions primarily impact immigration laws, several...more
On January 10, 2025, in a final action to, among other things, deter Russian aggression on the international stage, the US Department of the Treasury enacted sweeping new sanctions on the Russian energy sector. Specifically,...more
1/17/2025
/ Biden Administration ,
Blocking Sanctions ,
Economic Sanctions ,
Energy Sector ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
Popular ,
Renewable Energy ,
Russia ,
Sanctions ,
SDN List ,
U.S. Treasury
On November 26, 2024, the US Court of Appeals for the Fifth Circuit ruled that “immutable” smart contracts are not “property” for purposes of regulation by the US Department of the Treasury’s Office of Foreign Assets Control...more
12/19/2024
/ Appeals ,
Biden Administration ,
Blockchain ,
Chevron Deference ,
Cryptocurrency ,
Decentralized Autonomous Organization (DAO) ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Economic Sanctions ,
Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
Loper Bright Enterprises v Raimondo ,
Office of Foreign Assets Control (OFAC) ,
SCOTUS ,
SDN List ,
Smart Contracts
As the world prepares for the change of administration in January, current government officials and industry experts convened at the New York Forum on Economic Sanctions to reflect on enforcement trends in 2024, and to...more
12/10/2024
/ Anti-Money Laundering ,
Banks ,
Bureau of Industry and Security (BIS) ,
Cryptocurrency ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
National Security ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Self-Disclosure Requirements ,
Technology ,
Voluntary Disclosure
2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more
1/12/2024
/ Bureau of Industry and Security (BIS) ,
CFTC ,
Compliance ,
Economic Sanctions ,
Enforcement ,
European Anti-Fraud Office (OLAF) ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Self-Disclosure Requirements ,
Suspicious Activity Reports (SARs) ,
Voluntary Disclosure ,
Whistleblowers
The past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen...more
12/5/2023
/ Acquisitions ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Corporate Crimes ,
Corporate Misconduct ,
Cryptocurrency ,
Cyber Crimes ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Intellectual Property Protection ,
Investigations ,
Mergers ,
National Security ,
Recidivism ,
Remediation ,
Sanction Violations ,
Self-Disclosure Requirements ,
Terrorist Financing ,
Voluntary Disclosure ,
Whistleblowers