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Venezuela Sanctions: Wind-Down of General License 41 and Introduction of ‘Secondary Tariffs’

The dynamic pace of early policymaking by the new U.S. administration has continued into the spring of 2025, including in the context of sanctions on Venezuela. While Venezuela is not, and has not been, subject to...more

New US Sanctions and Ongoing OFAC Designations Enable the New Administration’s Policy Priorities

Policy change in Washington since the change in administration has been swift, dramatic in many areas and executed with unprecedented pace. One area, however, has been relatively stable in the administration’s first two...more

A Whirlwind of Change: The Delisting of Tornado Cash

Over the past several years, as U.S. regulators have grappled with the increasing use of cryptocurrency across a spectrum of legitimate and illegitimate commerce, the U.S. Department of Commerce’s Office of Foreign Assets...more

Further Sanctions Aim to Sever Remaining Ties Between Russia and U.S. Financial System

On November 21, 2024, the Biden Administration announced sweeping new sanctions targeting numerous Russian banks, financial institutions and officials, including one of the largest remaining unblocked Russian banks,...more

New Sanctions on Russia Mark Two-Year Anniversary of Ukraine Invasion

On February 23, 2024, the Biden Administration announced new sanctions targeting a number of different sectors of the Russian economy, Russian government officials and financial institutions, entities suspected of sanctions...more

OFAC Issues New General Licenses for Venezuela, Suspending Sanctions in Certain Sectors

On October 18, 2023 the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a set of new authorizations under the Venezuela sanctions regime, including a temporary suspension of...more

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