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 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
The U.S. Department of Commerce’s Bureau of Industry and Security has issued the final rule that will determine how its Information and Communications Technology and Services regulations will work going forward....more
4/25/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Enforcement Actions ,
Export Controls ,
Final Rules ,
Foreign Policy ,
Information Technology ,
National Security ,
Risk Assessment ,
Risk Management ,
Software ,
Supply Chain ,
U.S. Commerce Department ,
US Trade Policies
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
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 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
On February 10, President Donald J. Trump signed an executive order and accompanying fact sheet directing U.S. Attorney General (AG) Pam Bondi to pause the initiation of new investigations and enforcement actions, and to...more
2/18/2025
/ Anti-Corruption ,
Cooperative Compliance Regime ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Non-Prosecution Agreements ,
Regulatory Agenda ,
Regulatory Freeze ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
Whistleblowers
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