News & Analysis as of

Economic Sanctions Corporate Counsel

Husch Blackwell LLP

Summary of Tariff Requirements Updated: August 4, 2025

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Provided below is a status update and summary of tariffs that have been implemented since February 1, 2025, and impacts on imports from multiple countries. IEEPA (Fentanyl) Tariffs- IEEPA tariffs were announced on...more

Seward & Kissel LLP

OFAC Announces New Round of Sanctions Targeting Iran’s Energy Sector

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On the heels of the Trump administration’s June strikes on key nuclear sites in Tehran, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced significant new sanctions on July 30, 2025,...more

Bracewell LLP

FinCEN's Cartel Crackdown on Three Mexican Financial Institutions: Implications for US Financial Transactions

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It just got much riskier to do business in Mexico. On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a novel set of orders finding three financial institutions in...more

Baker Botts L.L.P.

Beyond the Fine: What Financial Gatekeepers Must Learn from Interactive Brokers’ OFAC Settlement

Baker Botts L.L.P. on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has significantly increased its focus on sanctions compliance for “financial gatekeepers,” including financial institutions and other firms...more

The Volkov Law Group

BIS Levies $4.25 Million Penalty Against Alpha and Omega Semiconductor for Unauthorized Exports to Huawei

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On June 27, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order resolving administrative enforcement proceedings against Alpha and Omega Semiconductor Incorporated (“AOS”), a...more

Kilpatrick

6 Key Takeaways | 2025 Mid-Year Review: Key Takeaways from U.S. Sanctions Enforcement Actions and Regulatory Updates

Kilpatrick on

In the first half of 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published 4 enforcement actions regarding apparent sanctions violations and also made some key updates to its...more

Foley Hoag LLP

Lessons from the First Four OFAC Sanctions Enforcement Actions under the Second Trump Administration

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Key Takeaways: - After a 5-month pause, OFAC recently announced four sanctions enforcement actions, making clear it is rigorously enforcing sanctions violations across a wide range of programs (including Russia, Iran,...more

Foley & Lardner LLP

What U.S. Businesses Need to Know About Reentering the Syrian Market & the Changing Post-Assad Sanction Landscape

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On May 23, 2025, approximately five months after the Assad regime was overthrown, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) officially issued Syria General License (GL) 25, which lifted the...more

Womble Bond Dickinson

[Webinar] Compliance Priorities for In-House Counsel: Responding to Latest DOJ Priorities & Guidance - August 5th, 3:00 pm - 4:00...

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Join us for an informative webinar providing the latest updates on key compliance issues under the current administration. Our panel will address recent developments in tariffs, the FCPA, False Claims Act, and sanctions....more

Wiley Rein LLP

Update: Enforcement of DOJ Data Security Program Set to Begin July 9

Wiley Rein LLP on

The U.S. Department of Justice (DOJ) is set to enforce its sweeping new rule on certain U.S. data transactions with countries of concern and covered persons as of July 9, 2025. The new rule regarding “Preventing Access to...more

Pillsbury - Global Trade & Sanctions Law

UK Expands Whistleblower Protections to Bolster Sanctions Enforcement

On June 26, 2025, the UK government brought into force the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 (the “2025 Amendment”), marking a notable development in the UK government’s sanctions...more

Morrison & Foerster LLP

DOJ Issues First-Ever Declination Under Corporate Disclosure M&A Policy

On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) announced that it declined to charge private equity firm White Deer Management LLC (“White Deer”) and its affiliates after the company...more

Pillsbury - Policyholder Pulse blog

When Politics Disrupt the Flow: What Policyholders Need to Know About Supply Chain and Political Risk Coverage

In today’s volatile global economy, companies are learning the hard way that political shocks—whether through trade sanctions, military conflict or abrupt regulatory change—can wreak havoc on supply chains. And worse, many...more

Hogan Lovells

RISK RADAR 2025 – Part 1: What’s keeping Middle East GCs awake and what to do about it

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With global tensions rising, data threats growing and regulators sharpening their teeth, 2025 is proving to be a significant year for legal and compliance teams across the Middle East. From secondary sanctions exposure to...more

Troutman Pepper Locke

Major OFAC Penalty for US Venture Capital Fund – Key Takeaways

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On June 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a civil penalty of approximately $216 million on GVA Capital Ltd., a venture capital firm based in San Francisco, for...more

ArentFox Schiff

So Long Syria Sanctions? Not So Fast!

ArentFox Schiff on

On May 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25, “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFSI Issues First-Ever Monetary Penalty for a Failure To Provide Information: Key Considerations for Companies

The Offence and Penalty - On 8 May 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) published its 11 April 2025 notice of its first-ever monetary penalty for an information offence relating to financial...more

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2024 Lessons Learned and 2025 Expectations

As the third month of the second Trump administration comes to a close, the lack of any public enforcement action by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctions watchers...more

Troutman Pepper Locke

Trump Administration’s First Export Control Action – Reading the Tea Leaves

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On March 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a significant expansion of its Entity List restrictions, adding 80 entities from China, the United Arab Emirates, South Africa,...more

Troutman Pepper Locke

Unprecedented "Secondary Tariffs" for Oil Trade With Venezuela

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On April 2 — labeled “Liberation Day” by President Trump — the Trump administration is set to add a new sanctions-like boost to its tariff strategy, with a threat to impose unprecedented “secondary tariffs” of 25% on “all...more

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

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On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more

Foley Hoag LLP

Adoption by the EU of the 16th Sanctions Package Against Russia: Key Takeaways

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The 16th package of European economic sanctions adopted and published in the Official Journal of the European Union (hereinafter the “EU”) on 24 February 2025 came into force on 25 February 2025. This 16th package of...more

Bracewell LLP

Trump Administration Makes First Round of Cartel Foreign Terrorist Organization Designations with Focus on Mexico and Venezuela

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The US State Department has made its first round of designations pursuant to Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists,”...more

Venable LLP

Key Trade Issues to Watch in 2025: A Preview Series

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As we look ahead to the new year and the many changes it will bring, the Venable International Trade and Logistics Group will be issuing a series of brief client alerts previewing key trade areas and issues to watch in 2025....more

Vinson & Elkins LLP

Citing Loper, Fifth Circuit Declines Agency Deference, Overturns Sanctions Against Cryptocurrency Software

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On November 26, 2024, the Fifth Circuit issued an opinion in Van Loon v. Department of the Treasury that invalidated economic sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on...more

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