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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

Maybe, Probably, Now (Sort of … ): New Tariffs Enter Into Force on Canada, Mexico and China … And May (or May Not) Be Here to Stay

Starting in February 2025, the Trump administration announced a series of actions providing itself with the legal authority to impose significant tariffs on trade in goods from Canada, China and Mexico (followed by a series...more

Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments

Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more

Safe Harbor in the Coming Enforcement Storm? DOJ Announces New M&A Policy to Encourage Compliance

On October 4, 2023, Deputy Attorney General Lisa Monaco (the “DAG”) announced a new Mergers & Acquisitions (“M&A”) Safe Harbor Policy issued by the Department of Justice (“DOJ”) as part of her comments detailing increased...more

DOJ OFAC BIS Joint Compliance Note and Enhanced Coordination Highlights Increased Enforcement Risk

On July 26, 2023, the U.S. Departments of Justice, Treasury, and Commerce issued a joint compliance note (“JCN”) regarding voluntary self-disclosure (“VSD”) policies that apply to potential violations of U.S. sanctions...more

OFAC-OFSI Enhanced Working Partnership

On 17 October 2022, the respective directors of the United Kingdom’s Office of Financial Sanctions Implementation (“OFSI”) and the United States’ Department of the Treasury Office of Foreign Assets Control (“OFAC”), Giles...more

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