• On October 23, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed the two Turkish government ministries and three ministers that it added to its Specially Designated Nationals and...more
10/25/2019
/ Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Syria ,
Trump Administration ,
Turkey
• A new Executive Order signed October 14, 2019, authorizes U.S. sanctions related to the military conflict between Turkey and Syria, providing broad authority to impose sanctions against Turkish government agencies,...more
On September 9, 2019, the Trump administration implemented additional U.S. sanctions on Cuba by restricting personal remittances to Cuba and eliminating authorization for U.S. banks to process “U-turn” transactions involving...more
9/11/2019
/ Banking Sector ,
Cross-Border Transactions ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Foreign Policy ,
Fund Transfers ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Personal Remittance Caps ,
Trump Administration ,
U-Turn Transactions ,
U.S. Treasury
• In a further escalation of U.S. sanctions on Venezuela in support of its efforts to oust the regime of Nicolás Maduro, on August 5, 2019, the Trump administration imposed comprehensive sanctions on the Government of...more
8/19/2019
/ Banking Sector ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration ,
Venezuela
• On August 8, OFAC issued Findings of Violation to two U.S. companies in relation to administrative subpoenas with follow-up responses deemed by OFAC to be inaccurate or incomplete.
• These recent actions build upon a...more
• The U.S. Department of State and the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) have imposed three new sanctions on Russia:
o Effective August 26, 2019, U.S. banks (as defined below) are...more
8/14/2019
/ Biological-Weapons ,
CBW Act ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Financial Institutions (FFI) ,
National Security ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sovereign Debt ,
Trump Administration
• On June 21, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued and put into effect an Interim Final Rule (Interim Rule) that requires all U.S. persons and persons subject to U.S....more
In a June 4 announcement, the Trump administration further ratcheted up U.S. sanctions and export controls against Cuba by prohibiting group “people-to-people” travel to Cuba and the use of noncommercial aircraft and...more
6/6/2019
/ Aircraft ,
Airline Passengers ,
Bureau of Industry and Security (BIS) ,
Cuba ,
Export Administration Regulations (EAR) ,
Federal Aviation Administration (FAA) ,
Foreign Relations ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Trump Administration ,
Vessels
• The U.S. Department of the Treasury's Office of Foreign Assets Controls (OFAC) recently published guidance that describes the framework for an effective Sanctions Compliance Program (SCP). In its guidance, OFAC makes clear...more
5/30/2019
/ Civil Monetary Penalty ,
Compliance ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Internal Controls ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Risk Mitigation ,
Sanctions ,
Senior Managers ,
U.S. Treasury ,
Voluntary Disclosure
• Yesterday, May 2, the United States government allowed implementation of Title III of the Helms-Burton Act, for the first time since the law was enacted in 1996, to permit U.S. nationals to sue persons that “traffic” in...more
5/3/2019
/ Banking Sector ,
Blocked Person ,
Cuba ,
Economic Sanctions ,
Financial Services Industry ,
Foreign Nationals ,
Foreign Relations ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Personal Jurisdiction ,
Risk Mitigation ,
Scope of Discovery Requests ,
Statute of Limitations ,
Trafficking ,
Travel Restrictions ,
Treble Damages ,
Trump Administration ,
U.S. Treasury ,
Visa Restrictions
• OFAC recently added a Moscow-based Russian-Venezuelan joint venture bank, Evrofinance Mosnarbank (“Evrofinance”), to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) for engaging in sanctions...more
3/29/2019
/ Banking Sector ,
Blocked Person ,
Economic Sanctions ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Joint Venture ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Trump Administration ,
Venezuela
• On January 28, 2019, OFAC added the Venezuelan state-owned oil and natural gas company PdVSA to its SDN List.
• As a result, U.S. persons are generally prohibited from engaging in transactions with PdVSA and entities that...more
2/6/2019
/ Blocked Person ,
Bonds ,
Capital Markets ,
Debt-Equity ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Securities Transactions ,
State-Owned Enterprises ,
Trump Administration ,
Venezuela
• On November 28, 2018, OFAC designated two Iran-based individuals who helped exchange cryptocurrency (bitcoin) into fiat currency on behalf of alleged ransomware perpetrators who targeted U.S. businesses and municipal...more
1/11/2019
/ Bitcoin ,
Blocked Person ,
Corporate Counsel ,
Crypto Exchanges ,
Cryptocurrency ,
Cyber Attacks ,
Cyber Crimes ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Digital Currency ,
Digital Wallets ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
SDN List ,
U.S. Treasury
• On November 27, 2018, the Trump administration issued an executive order establishing a new sanctions regime against Nicaragua.
• This occurs as the Trump Administration has articulated an approach to Latin America in...more
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
11/27/2018
/ Aircraft ,
Blocking Statutes ,
Cross-Border Transactions ,
Economic Sanctions ,
EU ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Humanitarian Assistance ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
SDN List ,
Special Purpose Vehicles ,
SWIFT ,
Trade Policy ,
Trump Administration ,
Vessels
• On September 20, 2018, for the first time, the Trump administration imposed sanctions on a non-U.S. entity and its director for engaging in “significant transactions” with a Russian defense sector company included on the...more
9/26/2018
/ Blocked Person ,
CAATSA ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Intelligence Services ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Secondary Sanctions ,
Suppliers ,
Trump Administration
In this podcast, Akin Gump’s international trade partners Mahmoud Baki “Mac” Fadlallah (Dubai), Jasper Helder (London) and Wynn Segall (Washington, D.C.) discuss three pivotal regions related to U.S. sanctions under the...more
• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more
8/17/2018
/ Blocking Statutes ,
Economic Sanctions ,
EU ,
Executive Orders ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Winding Down ,
Withdrawal
• On May 22, 2018, OFAC issued General License 15, authorizing U.S. persons to engage in specified transactions related to maintenance or wind-down of operations, contracts or other agreements involving GAZ Group or any...more
• On May 21, 2018, the Trump administration imposed new sanctions on the Government of Venezuela in response to the reelection of President Maduro and the “deepening humanitarian and public health crisis” fueled by the Maduro...more
• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more
5/10/2018
/ Controlled Foreign Corporations ,
Economic Sanctions ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trade Policy ,
Trump Administration
• On May 1, 2018, OFAC issued General License 13A authorizing the divestment or transfer of certain debt, equity or other holdings issued by EN+ Group, GAZ Group or United Company RUSAL PLC, as well as entities in which such...more
Today, OFAC issued General License 14, authorizing U.S. persons to engage in specified transactions related to maintenance or wind down of operations, contracts or other agreements involving RUSAL until October 23, 2018,...more
On April 6, 2018, the Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department sanctioned a number of Russian businessmen and companies, as well as Russian government officials and two state-owned entities. The...more
• On April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed seven prominent Russian businessmen, 12 companies, 17 senior Russian government officials, and a state-owned Russian...more
4/9/2018
/ Banking Sector ,
Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Government Officials ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Trump Administration ,
U.S. Treasury