News & Analysis as of

Office of Foreign Assets Control (OFAC) Sanctions

Foley Hoag LLP

U.S. Department of Commerce Issues Final Rule Relaxing Export Controls on Syria

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Key Takeaways: The Bureau of Industry and Security (“BIS”) has issued a final rule significantly relaxing export controls on Syria under the Export Administration Regulations (“EAR”), in line with Executive Order 14312, which...more

Venable LLP

Cryptocurrency Victory Amid a Shifting Political Environment: Lesser Charge Still Brings Important Ramifications for Decentralized...

Venable LLP on

On Wednesday, August 6, a Southern District of New York jury found Roman Storm, the founder of Tornado Cash, guilty of conspiracy to operate an unlicensed money-transmitting business in violation of Section 371 of Title 18 of...more

Arnall Golden Gregory LLP

Tariffs, Sanctions, and Trade Compliance: Insights from AGG’s Global Trade & Sanctions Team

In today’s unpredictable trade environment, where tariff policies and enforcement priorities change overnight, businesses face mounting pressure to keep supply chains resilient and compliant. AGG’s Global Trade & Sanctions...more

The Volkov Law Group

Episode 384 — Third-Party Risks and Sanctions

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With the beginning of the aggressive trade enforcement era, companies need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important. As we embark on a new criminal enforcement...more

Mayer Brown

Russia/Ukraine Sanctions Update - Month of August 2025

Mayer Brown on

I. U.S. SANCTIONS - U.S. Department of the Treasury Sanctions Russian Cryptocurrency Exchange: On August 14, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) re-designated the cryptocurrency...more

Mayer Brown

The Tornado Cash Trial’s Mixed Verdict: Implications for Developer Liability

Mayer Brown on

On August 6, 2025, following a four-week trial, a jury in the Southern District of New York delivered a mixed verdict in the criminal case against Tornado Cash co-founder Roman Storm. The jury convicted Storm of conspiring to...more

The Volkov Law Group

Lessons Learned in the New Aggressive Trade Enforcement Environment: Cadence Ignored Important Red Flags (Part III of III)

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Well, we are in a new era — a fundamental change has occurred, long in the making. National security and trade enforcement have coalesced to elevate trade risks — sanctions and export controls violations will be prosecuted...more

Stankie Law

Quarterly Trade Compliance Update – July 2025

Stankie Law on

Each quarter, I send my clients a trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. In addition to a variety of ad hoc...more

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

The Volkov Law Group

Episode 378 — Update on Export and Sanctions Enforcement Cases

The Volkov Law Group on

The Trump Administration is aggressively pursuing export controls and sanctions enforcement. In two separate cases, the Treasury Department’s Office of Foreign Asset Control and the Commerce Department’s Bureau of Industry...more

The Volkov Law Group

Episode 378 -- Update on Export Controls and Sanctions Enforcement

The Volkov Law Group on

What happens when companies ignore red flags, bypass legal advice, and underestimate the reach of U.S. export laws? In this episode, Michael Volkov unpacks two major enforcement actions from the Department of Commerce’s...more

Foley Hoag LLP

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

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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

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

A&O Shearman

U.S. DOJ first declination for sanctions violation since creation of M&A safe harbor

A&O Shearman on

On June 16, 2024, the U.S. Department of Justice’s (DOJ) National Security Division (NSD) and the U.S. Attorney’s Office for the Southern District of Texas (SDTX) announced the first-ever declination to prosecute a firm and...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

WilmerHale

Implications of EO 14157 and Recent “Foreign Terrorist Organization” and “Specially Designated Global Terrorist” Designations

WilmerHale on

On January 20, 2025, President Donald J. Trump signed Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists” (EO 14157)....more

Foley & Lardner LLP

The Non-Compliant Cat in the Hat

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So, just before Easter, in 1957, a little book you may have heard of, called The Cat in the Hat, made its first appearance. Theodore Geisel — writing under the name “Dr. Suess” — later said that of all his children’s books,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Understanding and Mitigating Legal and Compliance Risks Relating to Cartels and Transnational Criminal Organizations

On his first day in office, President Trump signed Executive Order 14157 calling for the designation of certain cartels and transnational criminal organizations (TCOs) as foreign terrorist organizations (FTOs) or specially...more

Bradley Arant Boult Cummings LLP

How the Trump Administration’s War on Cartels Will Reshape the Financial Sector

On March 11, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) aimed at disrupting drug trafficking and money laundering along the southwestern border. The...more

StoneTurn

Do You Know Who Your Employee Is? Mitigating DPRK IT Worker Risk

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North Korean IT operatives are infiltrating U.S. and Western companies using stolen or fabricated identities, VPNs, and U.S.-based co-conspirators to gain unauthorized access to corporate systems. These insider threats pose...more

Seward & Kissel LLP

President Trump Seeks “Maximum Pressure” on Iran Through Expansion of Sanctions Targeting Iran’s Oil Exports

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As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...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

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