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
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
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
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
7/25/2024
/ Cybersecurity ,
Economic Sanctions ,
Enforcement ,
EU ,
Export Controls ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Statute of Limitations ,
Trading with the Enemy Act ,
U.S. Treasury ,
UK ,
US Department of State
Broad authorizations permitting dealings in Venezuela’s oil and gas sector came to an end on April 17, 2024, when the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) terminated General...more
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
3/11/2024
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
PRC ,
Russia ,
SDN List ,
U.S. Treasury ,
US Department of State
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
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
8/4/2023
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
FinCEN ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
U.S. Commerce Department ,
U.S. Treasury ,
Whistleblowers
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