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China Boosts Enforcement of Anti-Foreign Sanctions Law

China has recently taken several actions showing its commitment to counter trade restrictions imposed by other countries. In March 2025, it released regulations implementing the 2021 Anti-Foreign Sanctions Law. In tandem with...more

Mitigating Risk From the Designation of Cartels as FTOs and SDGTs

The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more

Immutable Code Is Not Property: Fifth Circuit Reverses Tornado Cash Sanctions Ruling

The United States Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control ("OFAC") exceeded the authority granted by the International Emergency Economic Powers Act ("IEEPA") when it added the...more

Impact of Global Sanctions Regimes Relating to Russia, Ukraine, and Belarus

As a response to the Russian invasion of Ukraine starting in late February 2022, Australia, the European Union, Japan, the United Kingdom, the United States, and many other countries have progressively imposed increasingly...more

The Australian Parliament Enacts Magnitsky-style Laws

Australia's Existing Autonomous Sanctions Regime - Australia's existing autonomous sanctions regime is set out in the Autonomous Sanctions Act 2011 (Cth) ("Act")....more

OFAC Issues Additional Ransomware Guidance and Designates Virtual Currency Exchange

The U.S. Treasury Department has issued an updated ransomware advisory that highlights sanctions risks associated with ransomware payments and details proactive steps companies can take to mitigate these risks....more

China Enacts Law to Counter Foreign Sanctions

The Development: China's National People's Congress passed the Anti-foreign Sanctions Law (the "Anti-Sanctions Law") on June 10, 2021, which took effect immediately. The legislation was adopted by China in response to certain...more

New Sanctions Target Additional Sectors of Iranian Economy

The Situation: The Trump administration announced a new round of sanctions on January 10, 2020, following escalating tensions between the United States and Iran. The Result: The new sanctions complement existing sanctions...more

U.S. Imposes Sanctions on Turkish Officials, Ministries in Response to Syrian Offensive

The Situation: In response to events in Syria and in the face of strong Congressional pressure to act, President Trump introduced sanctions targeting Turkey. The Result: Although the President indicated that a ceasefire...more

President Trump Expands Sanctions Targeting Maduro Regime - "Embargo" order blocks property of Government of Venezuela and...

On August 5, 2019, President Trump signed Executive Order 13884 ("E.O. 13884") blocking the property of the Government of Venezuela and authorizing sanctions against a range of additional persons. In connection with E.O....more

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