News & Analysis as of

Office of Foreign Assets Control (OFAC) Economic Sanctions

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

Interactive Brokers Settles with OFAC for $11.8 Million for Violations of Multiple Sanctions Programs

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced on July 15, 2025, that Interactive Brokers LLC (“IB”)—a globally active electronic brokerage firm headquartered in Greenwich,...more

Stankie Law

Important Sanctions Compliance Lessons from OFAC’s $11.8m Settlement with Interactive Brokers

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On July 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with Interactive Brokers LLC (“Interactive Brokers”) violations of multiple U.S. sanctions...more

Foley Hoag LLP

Unpacking the U.S. Sanctions Reversal on Syria: Implications and Future Outlook

Foley Hoag LLP on

Key Takeaways: - Executive Order 14312 revokes the six executive orders that formed the foundation of the Syrian Sanctions Program, terminates the national emergency underlying those executive orders and waives and relaxes...more

Troutman Pepper Locke

M&A and Global Compliance Lessons From OFAC’s Settlement With Key Holding

Troutman Pepper Locke on

On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) reached a settlement with Key Holding, LLC (Key Holding) concerning its non-U.S. subsidiary’s violations of the Cuban Assets...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

K2 Integrity

The United States Terminates Countrywide Syria Sanctions and Is Working Towards Lifting Additional Trade Restrictions

K2 Integrity on

Building on prior relief of sanctions and other restrictive trade measures earlier this year (as described in K2 Integrity alerts dated 15 May and 09 June 2025), on 30 June 2025, U.S. President Donald Trump issued a new...more

Holland & Knight LLP

Executive Order Terminates Syria Sanctions, Directs Actions to Remove Other Trade Restrictions

Holland & Knight LLP on

President Donald Trump issued an Executive Order (the EO) on June 30, 2025, terminating the U.S. government's Syria sanctions program and directing other actions that, if finalized, will revoke the vast majority of U.S. trade...more

Stankie Law

Revocation of Syrian Sanctions: Opportunities, Risks, and Changes under Executive Order 14312

Stankie Law on

President Trump continued his flurry of sanctions actions with the recent revocation of the Syrian sanctions program. On June 30, 2025, President Donald Trump issued Executive Order (“EO”) 14312 “Providing for the Revocation...more

The Volkov Law Group

OFAC Imposes $608,825 Penalty on Key Holding, LLC for Apparent Violations of Cuban Sanctions Regulations

The Volkov Law Group on

On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had entered into a settlement agreement with Key Holding, LLC (“Key Holding”), a privately held logistics and...more

Morgan Lewis

FinCEN Issues First Transaction Ban on Certain Mexico-Based Financial Institutions

Morgan Lewis on

In a historic first, the US Department of the Treasury’s Financial Crimes Enforcement Network recently published orders prohibiting transactions with covered Mexico-based financial institutions. On June 30, 2025, the US...more

Thomas Fox - Compliance Evangelist

Regulatory Ramblings: Episode 73 - Geopolitical Risk: Thai Tensions / Sanctions, Tariffs & FCPA Enforcement in Asia

The conversation begins with Chris recounting the threats to Thailand’s security and stability, including the ongoing land border closure and standoff with Cambodia. He recounts with Regulatory Ramblings host Ajay Shamdasani...more

Foley Hoag LLP

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

Foley Hoag LLP on

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

Foley & Lardner LLP on

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

Skadden, Arps, Slate, Meagher & Flom LLP

A New Road to Damascus: Trump Administration Lifts US Sanctions on Syria

Pursuant to a sweeping new executive order (EO) issued on June 30, 2025, the Trump administration has lifted virtually all U.S. sanctions targeting Syria, shuttered the Syria sanctions program administered by the Office of...more

Fenwick & West LLP

United States Lifts Comprehensive Sanctions on Syria, Export Controls Remain For Now

Fenwick & West LLP on

On June 30, 2025, the White House issued Executive Order 14312, Providing for the Revocation of Syria Sanctions (the Syria EO), terminating U.S. comprehensive sanctions on Syria effective July 1, 2025. ...more

Morrison & Foerster LLP

FinCEN Targets Three Mexico-Based Financial Institutions with Sanctions Under New Authority to Address Money Laundering Associated...

On June 25, 2025, FinCEN issued its first orders under the 2024 FEND Off Fentanyl Act (FOFA), imposing special measures against three Mexican financial firms—CIBanco S.A., Institución de Banca Múltiple (CIBanco), Intercam...more

Katten Muchin Rosenman LLP

President Trump Issues Executive Order Lifting Longstanding Sanctions on Syria

On June 30, 2025, President Trump issued Executive Order 14312 (“E.O. 14312” or the “E.O.”) titled “Providing for the Revocation of Syria Sanctions,” which terminates, effective July 1, 2025, the longstanding U.S. sanctions...more

The Volkov Law Group

Episode 376 -- DOJ's Unicat Settlement and the Future Look of Trade Enforcement Actions

The Volkov Law Group on

What happens when a company inherits a sanctions violation through acquisition, and acts fast to fix it? Can a robust post-acquisition response really save a parent company from prosecution? In this episode, Michael...more

Wilson Sonsini Goodrich & Rosati

From Embargo to Engagement: U.S. Reopens Doors to Syria

After the fall of the former regime of Bashar al-Assad in Syria, the Presidential Administration has taken steps to formally dismantle the U.S.’s two-decade-long comprehensive trade restrictions on Syria. These steps began...more

Mayer Brown

FinCEN Designates Three Mexican Financial Institutions Under New Section 311 Authority: First Use of Expanded Powers Under FEND...

Mayer Brown on

On June 25, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued three orders (the “Orders”) pursuant to the Fentanyl Sanctions Act and the FEND Off Fentanyl Act, designating three...more

Bass, Berry & Sims PLC

Sanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition Disclosure

In June 2025, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced that Unicat Catalyst Technologies, LLC (Unicat), a Texas-based petrochemical company, had agreed to settle its potential civil liability...more

Troutman Pepper Locke

With Additional Syria Sanctions Relief, Risks Remain

Troutman Pepper Locke on

On June 30, 2025, President Trump issued an executive order (EO) that, effective July 1, revokes the U.S. sanctions program on Syria, and calls for the removal of the Syrian Sanctions Regulations from the Code of Federal...more

Kelley Drye & Warren LLP

White House Terminates Most Syria Sanctions

On June 30, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented the President’s Executive Order ​“Providing for the Revocation of Syria Sanctions,” (Syria EO) which removes U.S. sanctions on...more

Mayer Brown

Russia/Ukraine Sanctions Update - Month of June 2025

Mayer Brown on

I. U.S. SANCTIONS - Politico Reports President Trump Will Not Increase Sanctions on Russia to Maintain Peace Talks: On June 25, Politico reported that during an interview with Secretary of State, Marco Rubio, Secretary...more

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