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Economic Sanctions Corporate Counsel International Emergency Economic Powers Act (IEEPA)

Husch Blackwell LLP

Summary of Tariff Requirements Updated: August 4, 2025

Husch Blackwell LLP on

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

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

Troutman Pepper Locke on

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

Vinson & Elkins LLP

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

Vinson & Elkins LLP on

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

Baker Botts L.L.P.

OFAC Extends Recordkeeping Requirements for All Sanctions Programs

Baker Botts L.L.P. on

In an era of active U.S. sanctions policy, it is not uncommon to see the Office of Foreign Assets Control (“OFAC”) issue a notice changing U.S. sanctions – promulgating a new sanctions program or updating the designation of a...more

Morrison & Foerster LLP

War Aid and Sanctions: National Security Act Includes Significant New Sanctions Authorities

On April 24, 2024, President Biden signed into law a long-debated $98 billion foreign aid and national security legislative package (the “Act”) providing funds for Israel, Taiwan, and Ukraine, and authorizing new sanctions...more

Bass, Berry & Sims PLC

U.S. District Court Deals Rare Defeat to OFAC in U.S. Sanctions Matter

Bass, Berry & Sims PLC on

• $2 million penalty against Exxon overturned • Court concluded that OFAC failed to provide clear notice of violative conduct • Companies are at risk when acting in context of ambiguous agency guidance At the end of...more

Faegre Drinker Biddle & Reath LLP

Important New Guidance for Companies Considering Voluntary Disclosures of Export Control and Sanctions Violations

On December 13, 2019, the U.S. Department of Justice’s National Security Division (NSD) issued important new policy guidance regarding voluntary disclosures of export control and sanctions laws violations. Among other things,...more

Morgan Lewis

Federal Criminal Case Raises Provocative Questions on US Jurisdiction

Morgan Lewis on

Can the US government criminally prosecute non-US persons for activities that constitute secondary Iranian sanctions violations with no alleged nexus to the United States?...more

Skadden, Arps, Slate, Meagher & Flom LLP

"US Announces Record-Setting Penalties for Violations of Export Controls and Economic Sanctions"

On March 7, 2017, the United States announced that China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. and their respective affiliates (collectively, ZTE) had agreed to a record...more

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