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The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been relatively quiet on the enforcement front. That is not unusual — every transition results in an enforcement hiatus. Sanctions enforcement is a...more
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
As we wrote previously, the U.S. Department of the Treasury has issued a final rule that takes effect on December 26 that will dramatically raise the Committee on Foreign Investment in the United States (CFIUS) penalties from...more
August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more
On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more
On February 8, OFAC published Russia-related FAQ 1113 to clarify whether new investment prohibitions in Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 prohibit U.S. persons, including U.S. financial institutions,...more
I. OFAC Publishes FAQs Addressing Ban on New Investment in Russia On April 6, 2022, President Biden signed Executive Order (“EO”) 14071, which prohibits all “new investment in the Russian Federation by a United States...more
As the Russian invasion of Ukraine enters its fifth month, the United States continues to enact economic measures to discourage Russia from continuing hostilities, as well as impair their military operations in the country. ...more
The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our daily reporting of the evolving global sanctions campaign against Russia. This week, we reviewed the recent...more
Updated as of April 12, 2022 - It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed...more
On April 6, 2022, the United States and Europe announced new sanctions on Russian banks – Sberbank, the largest bank in Russia, and Alfa Bank, another large financial institution. The new Executive Order imposes full...more
I. New Executive Order Bans U.S. Investment in Russia - On April 6, 2022, President Biden issued a new Executive Order, “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to...more
The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our daily reporting of the evolving global sanctions campaign against Russia. ...more
On March 11, 2022, President Biden signed a new Russia-related Executive Order, Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression (“March 11 E.O.”)....more
The Office of Foreign Assets Control recently designated 7 “oligarchs,” 17 government officials, 13 companies, and one bank, all Russian, as Specially Designated Nationals (SDNs), effectively prohibiting US persons...more