“Secondary tariffs” strike again, with India now squarely in the crosshairs of the latest U.S. trade action. On August 6, President Trump issued an executive order “Addressing Threats to the United States by the Government of...more
8/8/2025
/ Ad Valorem Tax ,
Economic Sanctions ,
Effective Date ,
Executive Orders ,
Foreign Policy ,
Goods or Services ,
Imports ,
India ,
International Emergency Economic Powers Act (IEEPA) ,
Oil & Gas ,
Regulatory Reform ,
Russia ,
Tariffs ,
Trump Administration ,
US Trade Policies
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 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
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
On January 2, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) Export Enforcement published its 2024 Year in Review, spotlighting key accomplishments in protecting U.S. national security. In this...more
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
1/9/2025
/ Blocked Person ,
Compliance ,
Economic Sanctions ,
Energy Sector ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Russia ,
SDN List ,
U.S. Treasury
On November 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated Gazprombank, over 50 internationally connected Russian banks, more than 40 Russian securities registrars, and 15...more
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
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
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
On August 23, 2024, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) announced a series of new measures to further restrict the supply of U.S.-origin and "U.S.-branded" items to Russia and Belarus...more
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
On July 23, 2024, the U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) issued a new reporting requirement following the enactment of the Rebuilding Economic Prosperity and Opportunity for Ukrainians...more
Effective as of June 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced several additional export control restrictions and related actions against Russia and Belarus to further...more
On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new Determination Pursuant to Section 1 (a)(ii) of Executive Order 14071 (the “Determination”) that prohibits U.S....more
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
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
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
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
On December 22, 2023, President Biden ordered new U.S. sanctions against Russia by issuing Executive Order (“EO”) 14114 (“Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities”). EO 14114 amends...more
On December 22, 2023, President Biden issued new Executive Order (“EO”) 14114, amending EO 14024 and EO 14068. The new EO grants the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) authority to...more
On December 20, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General Licenses (“GL”) 81 and GL 82 under the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR...more
On December 12, 2023, the Department of the Treasury's Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State (“DOS”) sanctioned more than 250 individuals and entities by adding them to the List of...more
On December 1, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General Licenses (“GL”) 78 which authorizes limited safety and environmental transactions involving certain...more