Continuing with both its crackdown on cybercriminals and illicit digital marketplaces, along with its continued economic pressure on the Russian Federation, OFAC has sanctioned two entities that fit both criteria. On April...more
4/13/2022
/ Cryptocurrency ,
Currency Exchange ,
Cyber Crimes ,
Darknet ,
Economic Sanctions ,
Enforcement Actions ,
Military Conflict ,
Money Services Business ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Russia ,
Ukraine ,
Virtual Currency
On April 6, 2022, the United States and Europe announced new sanctions on Russian banks – Sberbank, the largest bank in Russia, and Alfa Bank, another large financial institution. The new Executive Order imposes full...more
Prosecutors and regulators are scouring their files for enforcement actions – criminal and civil – for violations of the 2014 Ukraine-Russia Sanctions Program. The message being sent is clear – do not violate any sanctions...more
Unsurprisingly, we’ve been fielding a significant number of inquiries regarding the latest Russian sanctions. Most companies seek black and white answers – what can we do and what can’t we do. However, sanctions are very...more
Keeping up with the Russia Sanctions and Export Controls is a challenge. Each day a new sanction or restriction is adopted with ripple actions by United States Allies and partners....more
3/18/2022
/ Biden Administration ,
Corruption ,
Economic Sanctions ,
Enforcement Guidance ,
Executive Orders ,
Export Controls ,
Foreign Policy ,
General Licenses ,
Luxury Goods ,
Military Conflict ,
Russia ,
Ukraine
In a much-anticipated action, President Biden announced a prohibition on all Russian oil and gas imports. The United States relies on Russia oil for approximately 8 percent of its needs....more
3/10/2022
/ Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Imports ,
Infrastructure ,
Military Conflict ,
Oil & Gas ,
Pipelines ,
Russia ,
UK ,
Ukraine ,
Vladimir Putin
The U.S. Attorney’s Office for the Southern Direct of New York recently announced the indictment of Jack Hanick, a United States citizen, of violating the U.S. sanctions against Russia and false statements in connection with...more
3/8/2022
/ Cable Television Providers ,
Crimea ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Extradition ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
SDN List
The Department of Justice has announced its plan to aggressively enforce the new Russia Sanctions Program. In response to the dire humanitarian situation in the Ukraine, DOJ took two significant actions – creation of the...more
3/7/2022
/ Biden Administration ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Priorities ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
Military Conflict ,
Russia ,
Ukraine ,
Vladimir Putin
As announced during his State of the Union, President Biden and U.S. Allies and partners, announced additional sanctions against Russia and Belarus. In recognition of the impact of the sanctions and export controls on the...more
3/3/2022
/ Airspace ,
Aviation Industry ,
Belarus ,
Belarus Sanctions ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
Oil & Gas ,
Russia ,
Ukraine ,
Vladimir Putin
The Russia-Ukraine crisis has created a fast-moving compliance nightmare – sanctions and export controls around the globe are changing each day. Some major companies are pulling out of Russia completely in response to the...more
3/3/2022
/ Asset Seizure ,
Biden Administration ,
Compliance ,
Economic Sanctions ,
EU ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
Ports ,
Russia ,
SWIFT ,
UK ,
Ukraine ,
Vladimir Putin
In a significant step, on Saturday, February 26, 2022, the United States and leaders of the European Commission, France, Germany, Italy, the United Kingdom, and Canada announced additional sanctions against key Russian...more
3/1/2022
/ Asset Freeze ,
Banking Sector ,
Biden Administration ,
Central Bank of Russia ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Russia ,
SWIFT ,
Trade Restrictions ,
UK ,
Ukraine ,
Vladimir Putin
In a significant step designed to increase financial pressure on Russia in response to its invasion of Ukraine, the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) issued new sanctions to prohibited United...more
3/1/2022
/ Asset Freeze ,
Banking Sector ,
Economic Sanctions ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sovereign Wealth Funds ,
Ukraine ,
Vladimir Putin
The Biden Administration announced a robust set of trade sanctions and export controls against Russia in response to the Russian invasion of Ukraine. The Treasury Department’s Office of Foreign Asset Control (“OFAC”) and the...more
2/28/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Ukraine ,
Vladimir Putin
Economic sanctions enforcement is a fast-rising risk for global companies. For many years, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) focused primarily on financial institutions. Over the last ten...more
Facing the myriad third-party sanctions risks can be daunting. Many global organizations rely on a network of third-party intermediaries that pose a variety of risks. To mitigate those risks, companies have to implement...more
The task of designing appropriate third-party sanctions controls requires reverse engineering of relevant caselaw, particularly, the Epsilon Electronics case, which I reviewed in Part I of this series, and the Department of...more
If there is one issue that is repeated over and over (and over), it is third-party risks. Over the last ten years, we have witnessed an explosion in anti-corruption enforcement around the world. And with this enforcement...more
OFAC is off to a quick start in 2022. After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in...more
1/21/2022
/ Compliance ,
Economic Sanctions ,
Failure to Comply ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Hong Kong ,
Internal Controls ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Risk-Based Approaches ,
Sanction Violations
President Putin is making sure that Russia dominates the early 2022 headlines. As Russia aligns its resources to invade Ukraine, the U.S. and European countries prepare to respond aggressively. It appears that nothing will...more
1/19/2022
/ Biden Administration ,
Critical Infrastructure Sectors ,
Economic Sanctions ,
Enforcement Priorities ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
Oil & Gas ,
Russia ,
SDN List ,
SWIFT ,
Ukraine ,
Vladimir Putin
The Treasury Department’s Office of Foreign Asset Control started off the new year with an interesting enforcement action against Airbnb Payments, Inc. (“Airbnb”), a money service business subsidiary of Airbnb, Inc. Airbnb...more
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been a steady performer in this challenging pandemic environment. Since the pandemic, OFAC has maintained a strong profile, while managing a difficult...more
The Treasury Department’s Office of Foreign Asset Control had another consistent year – not a big year but continued adherence to its enforcement program.
At the end of the year, OFAC announced a settlement with TD Bank...more
The United States Department of Commerce and Department of Treasury continue to ramp up sanctions against Chinese entities as part of the ongoing tension between China and the United States. ...more
1/7/2022
/ Bureau of Industry and Security (BIS) ,
China ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Supply Chain ,
Trade Relations ,
U.S. Commerce Department ,
U.S. Treasury ,
US Trade Policies
In May 2019, OFAC released its Framework for a Sanctions Compliance Program. OFAC announced that it intended to increase the prosecution of individuals for sanctions violations. OFAC has brought two cases against...more
In an interesting announcement, the US, EU, UK and Canada implemented additional sanctions against Belarus. The coordinated announcement reflected the Biden Administration’s diplomatic commitment to joint sanctions actions. ...more
12/21/2021
/ Asset Freeze ,
Canada ,
Economic Sanctions ,
Enforcement Actions ,
EU ,
Foreign Policy ,
Foreign Relations ,
Goods or Services ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Switzerland