News & Analysis as of

Office of Foreign Assets Control (OFAC) Trump Administration Corporate Counsel

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

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

Troutman Pepper Locke

Unprecedented "Secondary Tariffs" for Oil Trade With Venezuela

Troutman Pepper Locke on

On April 2 — labeled “Liberation Day” by President Trump — the Trump administration is set to add a new sanctions-like boost to its tariff strategy, with a threat to impose unprecedented “secondary tariffs” of 25% on “all...more

Holland & Knight LLP

Biden Administration Eases Some Trump-Era Cuba Restrictions

Holland & Knight LLP on

The U.S. Department of State announced on May 16, 2022, a series of measures aimed at supporting the Cuban people and independent Cuban entrepreneurs and loosening Trump-era restrictions that largely isolated the island and...more

Morrison & Foerster LLP

OFAC 2020 Year In Review

In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more

Dorsey & Whitney LLP

Trump Administration Bars U.S. Investments in Certain Chinese Companies Linked to Chinese Military

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On November 12, 2020, President Trump issued Executive Order 139591 (“the Order”) that will shortly bar any U.S. person from “any transaction in publicly traded securities, or any securities that are derivative of, or are...more

Morrison & Foerster LLP

OFAC 2019 Year In Review (Part 1 of 3)

As we enter 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) may need time to catch its breath after an exceptionally busy year. 2019 showed us that the Trump Administration continues to rely on...more

ArentFox Schiff

US Administration Tests the Water on New Unheard-of Government Review of International Technology Transactions

ArentFox Schiff on

Under this new evaluation process, Commerce can prohibit companies from engaging in a wide variety of transactions and order them to cease using the information technology or telecommunication system in question even if it is...more

Stoel Rives LLP

In Case You Missed It - Interesting Items for Corporate Counsel - May 2019

Stoel Rives LLP on

President Trump signed an executive order last week, here, designed to impose sanctions on the iron, steel, aluminum and copper sectors of Iran. The operative section of the EO reads like a crazy person Googled “sanctions”...more

Jones Day

Trump Administration Imposes Further Sanctions on Venezuela, Nicaragua and Cuba; Opens Helms-Burton Act Floodgate

Jones Day on

The Situation: On April 17, 2019, the Trump Administration announced additional sanctions targeting the so-called "troika of tyranny" – Venezuela and its key regional allies, Nicaragua and Cuba. These sanctions notably...more

Pillsbury - Global Trade & Sanctions Law

U.S. Targets Human Rights Abusers and Corrupt Actors Worldwide – Key Takeaways from the Potent New Sanctions

On December 20, 2017, President Trump issued Executive Order 13818 (the “E.O.”) implementing provisions of the Global Magnitsky Human Rights Accountability Act (“Global Magnitsky Act”) (enacted into law in December 2016),...more

Baker Donelson

New Sanctions Imposed For Human Rights Abuses and Corruption – a Harbinger For Business in 2018?

Baker Donelson on

On December 21, the U.S. Treasury Department announced the implementation of a new global sanctions regime under the Magnitsky Human Rights Accountability Act (the “Global Magnitsky Act”). President Trump issued an Executive...more

Sheppard Mullin Richter & Hampton LLP

The Table Flip: Trump, the Iran Nuclear Deal, and American Business

- A President Trump will have authority to reinstate sanctions lifted by the Iran Nuclear Deal as well as revoke certain authorizations provided for business with Iran. - Several economic and geopolitical factors may...more

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