News & Analysis as of

Office of Foreign Assets Control (OFAC) Foreign Policy Financial Institutions

Secretariat

Guardians of Finance Integrity, How the NY Fed’s Oversight in Iraq and Libya Could Hold a Blueprint for Post-Conflict...

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The Federal Reserve Bank of New York (FRBNY) has cemented its role as a global financial watchdog, using its influence to safeguard the integrity of the U.S. dollar and the broader international financial system. Recent...more

Paul Hastings LLP

New US Sanctions and Ongoing OFAC Designations Enable the New Administration’s Policy Priorities

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Policy change in Washington since the change in administration has been swift, dramatic in many areas and executed with unprecedented pace. One area, however, has been relatively stable in the administration’s first two...more

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

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Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

Woods Rogers

Designating Cartels as Terrorists: Potential Impact on U.S. Businesses

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On his first day in office, President Trump signed an executive order (EO 14157) that sets in motion the designation of certain cartels and transnational crime gangs as terrorist organizations. The President declared a...more

Baker Botts L.L.P.

Compliance, Enforcement, and Litigation Risk Considerations from President Trump’s Executive Order on Designating New Foreign...

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On January 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” The order directs the...more

Foodman CPAs & Advisors

BIS New Guidance for FI’s Best Practices

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On 10/9/24, the Bureau of Industry and Security (BIS) within the Department of Commerce has issued guidance aimed at financial institutions (FIs), outlining best practices for adherence to the Export Administration...more

Troutman Pepper Locke

OFAC Takes Further Action Against ‎Maduro-Aligned Officials ‎Following Venezuelan Election ‎Malfeasance

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On November 27, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned 21 high-ranking Venezuelan officials aligned with Nicolás Maduro. These sanctions, issued under Executive Order...more

The Volkov Law Group

OFAC Fines U.S. Person $1 Million for Multiple Violations of Sanctions Regime Against Iran

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In one of the more notable enforcement actions of 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently imposed a $1,104,408 civil penalty on a U.S. person for 75 separate violations...more

The Volkov Law Group

OFAC Imposes $860,000 Penalty on Vietnamese Beverage Company for Violations of North Korean Sanctions

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North Korea Sanctions Violations - In a recent enforcement action, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed an $860,000 penalty on Vietnam Beverage Company Limited (“VBCL”), a...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

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On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

Troutman Pepper Locke

OFAC Issues Warning to Financial ‎Institutions & Insurers That ‎Provide Maritime Services in the ‎Mediterranean, Red Sea and...

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Iran and Syria Sanctions and Embargos On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued updated guidance to remind maritime support service providers that the...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024

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In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...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

Fenwick & West LLP

U.S. Imposes Sweeping New Sanctions and Export Controls on Russia and Belarus, including on Certain Software and Related Services

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Citing Russia’s “transition to a full war economy,” the United States imposed sweeping new sanctions and export controls on Russia and Belarus today, including companies and individuals that continue to supply Russia’s...more

Eversheds Sutherland (US) LLP

US sanctions hundreds of targets on two-year anniversary of Russia’s invasion of Ukraine and in response to Aleksei Navalny’s...

Contemporaneous with the European Union’s adoption of its 13th package of Russia sanctions, on February 23, 2024, the United States imposed sanctions against nearly 500 targets in continued response to Russia’s aggression...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed on the Russian Federation and Covered Regions of Ukraine in Response to the...

BakerHostetler on

In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more

Troutman Pepper Locke

U.S. Issues Warning to Foreign ‎Financial Institutions That Assist Russia’s War Machine

Troutman Pepper Locke on

On December 22, 2023, President Biden issued new Executive Order (“EO”) 14114, amending EO 14024 and EO 14068. The new EO grants the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) authority to...more

Kelley Drye & Warren LLP

White House Broadens Restrictions on Russia by Authorizing Sanctions on Foreign Financial Institutions and Expanding the Import...

On December 22, 2023, President Biden signed Executive Order 14114, titled ​“Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities” (EO 14114), with a focus on holding foreign financial...more

Ballard Spahr LLP

Steel Company President with Ties to Russian Oligarch Pleads Guilty to Money Laundering Conspiracy Involving Alleged Sanctions...

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Earlier this month, John Can Unsalan, the president of a steel-making company with ties to Russian oligarchs, pled guilty to one count of conspiracy to commit money laundering, based on financial transactions committed with...more

Ballard Spahr LLP

FinCEN Analysis Reveals Patterns and Trends in Suspected Evasion of Russia-Related Export Controls

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Following Russia’s invasion of Ukraine, the Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a joint alert and a supplemental alert (the...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

Orrick, Herrington & Sutcliffe LLP

OFAC sanctions additional persons in Bosnia and Herzegovina

On March 15, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against three individuals in Bosnia and Herzegovina (BiH), pursuant to Executive Orders 14033 or 14059. ...more

Troutman Pepper Locke

OFAC Russia Related Sanctions Update: ‎August 2022 #2

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On August 19 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended Russia-related General License (“GL”) 38A (GL 38A) and issued a new GL (GL 50) related to the Russian Harmful Foreign...more

A&O Shearman

Sanctions Round Up: Second Quarter 2022

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With the war in Ukraine raging on, the U.S. continued to escalate its sanctions response against Russia. The U.S. announced extensive trade and investment bans that prohibit U.S. persons from making any “new investment” in...more

Troutman Pepper Locke

OFAC Russia Related Sanctions Update: ‎‎July 2022‎ #3

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On July 22, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) (1) issued two new Russia-related General Licenses (“GL”) (GL 45 and GL 46), (2) published two new FAQs (FAQ 1071 and FAQ...more

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