On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) reached a settlement with Key Holding, LLC (Key Holding) concerning its non-U.S. subsidiary’s violations of the Cuban Assets...more
7/15/2025
/ Acquisition Agreements ,
Cuban Assets Control Regulations (CACR) ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Subsidiaries ,
International Trade ,
Merger Agreements ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Sanctions ,
U.S. Treasury
On June 30, 2025, President Trump issued an executive order (EO) that, effective July 1, revokes the U.S. sanctions program on Syria, and calls for the removal of the Syrian Sanctions Regulations from the Code of Federal...more
On June 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a civil penalty of approximately $216 million on GVA Capital Ltd., a venture capital firm based in San Francisco, for...more
6/17/2025
/ Civil Monetary Penalty ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Investment ,
Investment Funds ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Subpoenas ,
Venture Capital
On May 23, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License 25 (GL 25), effectively lifting most sanctions imposed under the Syrian Sanctions Regulations (SSR) (31...more
The Treasury Department has taken initial steps to implement the Trump administration’s “total elimination” policy directed at certain drug trafficking cartels. Most recently, on May 1, Treasury’s Financial Crimes Enforcement...more
5/9/2025
/ Border Security ,
Cartels ,
Crude Oil ,
Economic Sanctions ,
Financial Crimes ,
FinCEN ,
Foreign Trade Regulations ,
Mexico ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Smuggling ,
Terrorist Acts
In this episode of Crypto Exchange, host Ethan Ostroff is joined by his colleagues Pete Jeydel and Peter Leary to discuss trends and lessons learned from recent civil enforcement actions by the Treasury Department's Office of...more
Under the Department of Justice’s (DOJ) “Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons” rules (the Rules), allowing access outside the United States...more
4/4/2025
/ China ,
Data Security ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Final Rules ,
National Security ,
New Regulations ,
Personal Data ,
Regulatory Reform ,
Russia ,
Trump Administration
On March 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a significant expansion of its Entity List restrictions, adding 80 entities from China, the United Arab Emirates, South Africa,...more
3/28/2025
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Machine Learning ,
National Security ,
Regulatory Reform ,
Technology Sector ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
On April 2 — labeled “Liberation Day” by President Trump — the Trump administration is set to add a new sanctions-like boost to its tariff strategy, with a threat to impose unprecedented “secondary tariffs” of 25% on “all...more
3/28/2025
/ Corporate Counsel ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Infrastructure ,
Mexico ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Regulatory Oversight ,
Secondary Sanctions ,
Secretary of Commerce ,
Tariffs ,
Trump Administration ,
U.S. Commerce Department ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies ,
Venezuela
On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more
3/26/2025
/ Anti-Money Laundering ,
BSA/AML ,
Corporate Counsel ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
EU ,
Final Rules ,
Financial Institutions ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Regulatory Reform ,
Regulatory Requirements ,
Terrorist Financing Regulations ,
Trading with the Enemy Act ,
U.S. Treasury
On March 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) allowed General License (GL) 8L under the Russian Harmful Foreign Activities Sanctions Regulations to expire. As a result, broad OFAC...more
3/14/2025
/ Banks ,
Biden Administration ,
Biofuel ,
Economic Sanctions ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Prohibited Transactions ,
Russia ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
U.S. Treasury
The Trump administration continues to ramp up sanctions on Venezuela and Yemen's Houthis, while sending mixed signals about its intentions with respect to Russia. We provide brief updates on these three areas, following up...more
3/11/2025
/ Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Regulatory Reform ,
Russia ,
Terrorist Organizations ,
Trump Administration ,
U.S. Treasury ,
US Trade Policies ,
Venezuela ,
Yemen
With an array of unprecedented executive orders and other policies, the Trump administration’s “America First” trade strategy is beginning to take shape. As we monitor these developments, it is becoming increasingly clear...more
3/4/2025
/ CFIUS ,
China ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Forced Labor ,
Foreign Investment ,
ITAR ,
National Security ,
Popular ,
Trump Administration ,
US Trade Policies ,
Uyghur Forced Labor Prevention Act (UFLPA)
On February 20, 2025, the U.S. Departments of State and the Treasury designated eight Latin American drug trafficking cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), in...more
2/25/2025
/ Anti-Terrorism Financing ,
Cartels ,
Cooperative Compliance Regime ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
SDN List ,
Terrorist Financing Regulations ,
Trafficking ,
Trump Administration
We find ourselves in the midst of a raucous debate among sanctions practitioners about the impact of the Fifth Circuit’s recent decision upholding a challenge against the sanctions the Office of Foreign Assets Control (OFAC)...more
2/5/2025
/ Blockchain ,
Cryptocurrency ,
Decentralized Autonomous Organization (DAO) ,
Digital Assets ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Financial Transactions ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Statutory Interpretation
Days before President Biden leaves the White House, the U.S. government has delivered a major blow against Russia. On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced...more
1/17/2025
/ Biden Administration ,
Economic Sanctions ,
Energy Sector ,
Export Controls ,
Foreign Policy ,
Infrastructure ,
Liquid Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
U.S. Treasury