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OFAC Removes Sanctions on Turkish Ministries and Ministers; U.S. Executive Order Providing a Basis for Sanctions on Turkey Remains...

• 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

U.S. Government Authorizes Economic Sanctions on 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

Treasury Imposes Additional Restrictions on Remittances to Cuba and “U-Turn” Transactions

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

Trump Administration Imposes Broad Sanctions on the Government of Venezuela

• 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

New U.S. Sanctions Penalties Spotlight Sanctions and Export Controls Scrutiny of False and Incomplete Statements

• 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

Second Round of U.S. Sanctions on Russia Pursuant to the Chemical and Biological Weapons Control Act

• 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

OFAC Issues Interim Final Rule Extending Reporting Requirements for Rejected Transactions to Companies Outside the Financial...

• 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

New Cuba Sanctions Measures Prohibit “People to People” Travel to Cuba and Restrict Use of Commercial Aircraft and Recreational...

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

OFAC’s New Framework for an Effective Sanctions Compliance Program Provides Important Risk Mitigation Advice

• 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

Recent U.S. Sanctions Designations Create Additional Risks for Companies Doing Business with Venezuela

• 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

OFAC Sanctions Venezuelan State-Owned Energy Company PdVSA, Releases New General Licenses and FAQs for Venezuela Sanctions Regime

• 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

OFAC Adds Iranian Bitcoin Exchangers’ Names and Wallet Addresses to SDN List, Ushers in “New Approach” to Sanctions Enforcement

• 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

New U.S. Sanctions Regime Targeting Nicaragua

• 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

Iran Sanctions Are Here—Breaking Down What This Means For Business

• 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

Trump Administration Sanctions Chinese Entity and its Director in First Imposition of Secondary Sanctions under Section 231 of...

• 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

Podcast: U.S. Sanctions and Their Impact on Non-U.S. Businesses

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

President Trump Issues New Iran Executive Order and Reimposes First Set of Sanctions Following JCPOA Withdrawal

• 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

OFAC Issues General License 15 Expanding and Extending Authorized Activities with GAZ Group Until October 23, 2018

• 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

United States Imposes New Sanctions Restricting Transactions with the Government of Venezuela

• 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

President Trump Announces U.S. Withdrawal from JCPOA; U.S. Sanctions on Iran will be Re-imposed Following Wind-Down Periods

• 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

OFAC Issues Updated General Licenses Clarifying and Extending Authorized Activities with Russian Sanctioned Entities

• 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

OFAC Issues General License Expanding and Extending Authorized Activities with RUSAL Until October 23, 2018

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

New Sanctions on Russian Businessmen: Impact on Investment Funds

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

OFAC Sanctions Leading Russian Businessmen, Government Officials and Companies

• 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

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