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Financial Transactions Related to Russian Energy Now Prohibited: Expiration of OFAC ‎General License 8L

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

Latest Sanctions Developments: Venezuela, Russia, and Yemen

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

OFAC's Latest General Licenses and FAQs Related to Russian Sanctions

On December 18, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 1B (Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue...more

OFAC Updates General Licenses and ‎FAQ on PdVSA 2020 8.5% ‎Bonds

On November 7, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 5Q ("Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5...more

OFAC Issues Russia Sanctions General ‎Licenses and FAQs ‎Related to Securities Held at the National ‎Settlement Depository

On October 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Frequently Asked Question (“FAQ”) 1197 on securities held at the National Settlement Depository (“NSD”) in connection...more

OFAC Issues Global Magnitsky ‎Sanctions Relief for Ly Young Phat Group and FAQs

On September 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 8 alongside amendments to various Frequently Asked Questions (“FAQs”) in connection with the...more

OFAC Issues FAQs for IT and Software ‎‎Services and Extends Authorization to Engage in ‎Administrative ‎Transactions in Russia

On September 24, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three frequently asked questions (“FAQs”) that provide guidance to U.S. companies regarding the Determination...more

OFAC Issues General Licenses, Updates FAQ, and Issues New Blocking Rule and Reminder to File Annual Blocked Property Report

On September 5, 2024, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) released General License (“GL”) 108 (“Authorizing Limited Safety and Environmental Transactions Involving Certain Blocked...more

OFAC Amends Cuban Assets Control Regulations and Issues New FAQs for U-Turn Transactions

On August 27, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced amendments to two key FAQs (FAQs 736 and 757) concerning the Cuban Assets Control Regulations (“CACR”). These FAQs...more

What Do Diamonds, Safety and the Environment Have in Common? OFAC New General Licenses and FAQs

On August 23, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 103 ("Authorizing Transactions Related to Imports of Certain Diamond Jewelry Prohibited by...more

OFAC Extends and Issues General Licenses Involving Russian Tax and Civil Aviation Safety

The U.S. Department of the Treasury’s Office of Foreign Asset Control ‎‎(“OFAC”) on (i) July 10, 2024, extended General License (“GL”) 13J (“Authorizing Certain Administrative Transactions Prohibited by Directive 4 under...more

OFAC Continues Restrictions Blocking ‎Enforcement of CITGO-Backed PdVSA Bonds

An August 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) further delayed to November 12, 2024, U.S. persons’ rights as bondholders of Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5%...more

OFAC Extends General License to Allow ‎Export Liquefied Petroleum ‎Gas to PdVSA for Humanitarian Aid

The Venezuela Sanctions Regulations, 31 CFR Part 591 (“VSR”), which was enacted pursuant to Executive Order (“EO”) 13850 of November 1, 2018 (“Blocking Property of Additional Persons Contributing to the Situation in...more

OFAC Extends General License for GL ‎‎99A Entities and Issues New GL for VPower in Hong Kong

On August 2, 2024, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License ("GL") 99A, which authorizes through October 12, 2024, the wind-down of transactions...more

OFAC Extends Venezuela-Related ‎General License for Limited Maintenance of Essential Operations and Wind-Down

On May 10, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets (“OFAC”) amended General License (“GL”) 8N related to Venezuela Sanctions Regulations, 31 CFR part 591....more

OFAC Targets Russia’s Military-‎Industrial Base and Third-‎Country Supporters, and Issues ‎Related General Licenses

On April 29, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published General License (“GL”) 8I related to the‎ ‎Russian Harmful Foreign Activities ‎Sanctions Regulations, 31 CFR Part...more

Joint U.S. – U.K. Measures Target ‎Russian Metal Exports: Prohibitions and Implications

On December 6, 2023, and February 24, 2024, the G7 Leaders announced their intention to diminish Russia’s earnings from metal exports. On April 12, 2024, in collaboration with the United Kingdom the United States introduced...more

OFAC Revokes Sanctions Suspension on Venezuela’s Oil & Gas Sector, and Extends Prohibitions to Act on PdVSA 8.5% Bonds’ CITGO...

An April 17, 2024, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) issued General License (“GL”) 44A (“Authorizing the Wind Down of Transactions Related to Oil or Gas Sector Operations in...more

OFAC Reissues Global Magnitsky ‎Sanctions Regulations

On March 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended and reissued the Global Magnitsky Sanctions Regulations (the “Regulations”) to further the Global Magnitsky Human...more

OFAC Tightens Sanctions Related to Venezuela Non-Commercial Flights

On February 29, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets (“OFAC”) amended General License (“GL”) 45B related to Venezuela Sanctions Regulations, 31 CFR part 591. Subsequently, on March 1, 2024,...more

U.S. Announces New Sanctions Against ‎Russia Following Ukraine-‎Russia War 2-Year Anniversary and ‎the Death of Aleksey Navalny

In response to the second anniversary of Russia’s illegal war against Ukraine and the death of political opposition leader and anti-corruption activist Aleksey Navalny, the United States Department of the Treasury’s Office of...more

OFAC Oil Price Cap Alert, OPC ‎Violations, and Russian Diamond Ban

On February 1, 2024 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a comprehensive "Oil Price Cap Compliance and Enforcement Alert" (the “Alert”) to bolster enforcement of the Russian...more

OFAC Revokes Venezuela Gold Mining ‎General License and Threatens to Reimpose Oil and Gas ‎‎Sanctions

On January 29, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) revoked General License (“GL”) 43 and issued GL 43A (“Authorizing the Wind Down of Transactions Involving CVG Compania...more

OFAC Sanctions New Russian Price Cap ‎Violator and Publishes General Licenses and FAQ

On January 18, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated Hennesea Holdings Limited (“Hennesea”) and multiple vessels owned by Hennesea to the Specially Designated...more

GL 6N Extends to April 2024 the ‎Moratorium That Prohibits ‎Holders of PdVSA 8.5% Bonds From ‎Acting on CITGO Collateral

On January 16, 2024, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) issued General License (“GL”) 5N (Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5...more

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