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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

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

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

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

WilmerHale

Recent Developments in UK Sanctions

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After a relatively quiet period, UK sanctions updates have picked up pace in recent weeks. We have seen the announcement of an enhanced partnership between US and UK sanctions agencies, updates to reporting requirements, the...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Sanctions Puzzle: Key Areas To Watch in 2025 and Beyond

The past weeks and months have brought about tremendous political change in the West, as we move toward a new U.S. administration, a new College of Commissioners in Brussels and a new Polish presidency of the Council of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFSI Issues First Monetary Penalty for Breach of Sanctions Imposed on Russia in Response to Its Invasion of Ukraine

On 27 September 2024, the UK’s financial sanctions regulator, the Office of Financial Sanctions Implementation (OFSI), announced that it had issued its first monetary penalty for a breach of UK financial sanctions imposed...more

Dorsey & Whitney LLP

Biden Administration Again Expands Sanctions on Russia and Its Third Party Supporters

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As Russia continues its war against Ukraine and Ukraine has itself recently opened a new front by capturing Russian territory in its Kursk region, the United States announced on August 23 its latest tranche of sanctions...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

Skadden, Arps, Slate, Meagher & Flom LLP

EU’s 14th Sanctions Package: Compliance Obligations Expand and Exits Are Facilitated

On 24 June 2024, the European Union (EU) adopted its 14th sanctions package directed against Russia, imposing an asset freeze against an additional 116 individuals and entities and expanding sectoral sanctions targeting key...more

Pillsbury - Global Trade & Sanctions Law

EU’s 14th Package of Sanctions on Russia

On 24 June 2024, the EU adopted its 14th package of sanctions against Russia. The latest measures include: The designation of 116 additional individuals and entities across a number of industries for their responsibility in...more

Hogan Lovells

New EU Sanctions Reporting Obligations in Force as of 1 May 2024 and 1 June 2024

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The new EU notification requirements relating to transfers of funds out of the EU by EU entities with a certain level of direct or indirect Russian ownership enters into force soon. The reporting obligation has a broad scope,...more

Morrison & Foerster LLP

OFAC Issues Omnibus Accounts Enforcement Case Involving Russia and Other Sanctions Programs

On March 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its first enforcement case of the year and its first ever involving dealings with a Russian designated for sanctions...more

Morrison & Foerster LLP

EU Sanctions Year in Review 2023

In 2023, the European Union continued to use economic sanctions as one of its foreign policy tools, and not only in response to Russia’s war in Ukraine. New sanctions and adjustments to existing regimes reflect the EU’s...more

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2023 Trends and Lessons Learned

Today’s alert—the second in our Sanctions 2023 Year in Review Series—provides an overview of U.S. sanctions enforcement in 2023, including the key lessons learned from the public enforcement actions issued by the U.S....more

Morrison & Foerster LLP

OFAC Year in Review 2023 – Part 1

2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more

A&O Shearman

U.S. Imposes New Russia Sanctions and Export Controls and Warns of Risk of Continued Business with Russia

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On February 23, 2024, the United States imposed its largest number of new sanctions and export control designations against Russia to date—targeting over 600 individuals and entities across a wide swath of the Russian economy...more

Mayer Brown

UK Government to launch new unit to enforce export controls and trade sanctions

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On 11 December 2023, the UK Government announced plans to create the Office of Trade Sanctions Implementation (OTSI), a new governmental body that will be responsible for inter alia the civil enforcement of UK trade...more

K&L Gates LLP

New Government Guidance and UK High Court Seeks to Settle Disarray in UK Sanctions Law

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In October, the Court of Appeal suggested all companies operating in Russia could be considered to be sanctioned under UK law because they are potentially controlled by President Putin. This caused understandable alarm to...more

Faegre Drinker Biddle & Reath LLP

First Significant UK Sanctions Judgment Handed Down

Background - In response to Russia’s invasion of Ukraine in February 2022 the UK, in parallel with the U.S. and the EU, significantly expanded its sanctions against Russia by imposing wide restrictions on trade, aircraft,...more

Vinson & Elkins LLP

S.D.N.Y. Awards Aircraft Owner Over $406 Million for Aircraft and Engines Trapped in Russia

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U.S. companies that found their assets caught up in Russia at the start of the Russia/Ukraine conflict may find relief on paper from U.S. courts. But it remains to be seen whether they can recover in practice....more

Fenwick & West LLP

U.S. Government Imposes New Export Controls and Sanctions on Russia and Belarus

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On May 19, 2023, the Biden administration announced another major round of U.S. sanctions and export controls against Russia and Belarus in response to the ongoing war in Ukraine, in coordination with the G7 Leaders’ Summit...more

A&O Shearman

Russian Countersanctions: New Measures Targeting Foreign Investors in Russia

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Fourteen months into the Ukraine war, the Russian Government has introduced new countersanctions targeting foreign investors in Russia. The latest measures require businesses from “unfriendly” countries to make a “voluntary...more

Orrick, Herrington & Sutcliffe LLP

Three Signs of a New Era in U.S. Export Controls and Sanctions Enforcement

In light of Russia’s invasion of Ukraine and intensifying strategic competition with China, the U.S. government is prioritizing enforcement of export controls and economic sanctions in unprecedented ways. We expect higher...more

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