News & Analysis as of

U.S. Treasury International Emergency Economic Powers Act (IEEPA)

Kelley Drye & Warren LLP

Supreme Court Denies Request to Fast-Track Reciprocal Tariffs Case

On Friday June 20, the U.S. Supreme Court denied a motion in an IEEPA / reciprocal tariff litigation case that sought to bypass the DC Circuit Court of Appeals and have the Supreme Court hear the case early. So, for the time...more

Benesch

Syria Sanctions - New General License Issued by OFAC Following Trump Announcement

Benesch on

President Trump announced plans to relax sanctions against Syria during his recent trip to the Middle East, where he visited with the country’s President, Ahmed al-Sharaa. ...more

Miles & Stockbridge P.C.

Lifting Sanctions On Syria: A Preview of the Process

President Donald Trump announced Tuesday during his trip to the Middle East that his administration would lift U.S. sanctions on Syria. Since the shock collapse of Bashar al-Assad’s regime in Syria late last year, the...more

Warner Norcross + Judd

A 90-Day Reprieve in U.S./China Trade Relations

Warner Norcross + Judd on

On May 11, 2025, the United States and China concluded their trade negotiations in Geneva, Switzerland. Both countries agreed to make certain “beneficial economic” commitments to deescalate the trade war, the most important...more

Troutman Pepper Locke

OFAC Recordkeeping Requirement Extended to 10 Years

Troutman Pepper Locke on

On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule extending the recordkeeping requirements under OFAC’s regulations from five years to 10 years. This change...more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

K2 Integrity on

On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more

K2 Integrity

Escalation Against Cartels: U.S. Designates International Cartels as Foreign Terrorist Organizations and Specially Designated...

K2 Integrity on

On 20 February 2025, the United States (U.S.) Department of State designated eight international cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs). The designation of...more

Latham & Watkins LLP

Trump Administration Targets Cartels With First Wave of Terrorism Designations

Latham & Watkins LLP on

The designations expand US tools and jurisdictional reach, and raise the stakes for foreign financial institutions and non-US companies to avoid dealing with designated entities....more

DLA Piper

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

DLA Piper on

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

Latham & Watkins LLP

White House Issues America First Investment Policy

Latham & Watkins LLP on

The policy memo aims to preserve an open investment environment as well as restrict investment in strategic sectors. Late on Friday, February 21, 2025, the White House released its “America First Investment Policy”...more

Hogan Lovells

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

Hogan Lovells on

The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more

DLA Piper

White House Executive Orders Impacting Tax and Trade – Developments of the Week of January 27, 2025

DLA Piper on

A range of White House Executive Orders (EOs) are likely to impact tax and trade policy. In this alert, DLA Piper’s Tax and Trade policy team provides updates and insights on relevant policy developments from the week of...more

Hogan Lovells

“America First Trade Policy” memorandum directs a comprehensive review of U.S. trade policy, suggests potential new tariffs and...

Hogan Lovells on

President Trump’s Day 1 presidential memorandum directs a top-to-bottom review of U.S. trade and economic policy and requests that his Administration provide policy recommendations with respect to: the U.S. trade deficit and...more

Wiley Rein LLP

President Trump Issues “America First” Trade Policy and Previews Additional Tariffs on Canada, Mexico, and China - UPDATED 1/22/25

Wiley Rein LLP on

This alert was originally published on January 21, 2025, and updated on January 22, 2025, to reflect President Trump’s comments that additional 10% tariffs may be imposed on China on February 1. On January 20, 2025,...more

Cozen O'Connor

Cozen Currents: Shock and Awe

Cozen O'Connor on

“While Republicans have taken unified control of the federal government, President-elect Donald Trump is going to lean heavily on an expansive use of executive power from his first day back in the Oval Office as he has...more

BCLP

Fifth Circuit Rules OFAC Cannot Sanction Tornado Cash: Loper Bright Hamstrings OFAC’s Campaign Against Crypto Laundering

BCLP on

Shortly before Thanksgiving, a panel of the United States Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) did not have the authority to sanction Tornado Cash, which offers a...more

Cozen O'Connor

Cozen Currents: America First 2.0

Cozen O'Connor on

“President-elect Trump is re-entering the Oval Office with an even bolder and more muscular approach to his America First policies. But Trump’s policymaking isn’t the only thing to have evolved over the past four years – so...more

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Overturns OFAC Sanctions on Blockchain-based Privacy Technology

On November 26, the U.S. Fifth Circuit Court of Appeals overturned sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) against a decentralized cryptocurrency mixing service (a...more

Ballard Spahr LLP

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

Ballard Spahr LLP on

In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado...more

Vinson & Elkins LLP

Citing Loper, Fifth Circuit Declines Agency Deference, Overturns Sanctions Against Cryptocurrency Software

Vinson & Elkins LLP on

On November 26, 2024, the Fifth Circuit issued an opinion in Van Loon v. Department of the Treasury that invalidated economic sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on...more

Troutman Pepper Locke

OFAC Issues New and Amended FAQs ‎for the Insurance ‎Industry

Troutman Pepper Locke on

On November 13, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended several insurance-related Frequently Asked Questions (“FAQs”) (61, 62, 63, 64, 65, 68, 69, 102, 103, and 104) as...more

Sheppard Mullin Richter & Hampton LLP

At Long Last, Final Rule for Outbound Investment Regulations Published

On October 28, 2024, the U.S. Department of Treasury released a pre-publication version of its final rule containing the outbound investment regulations. The rule arrives a little over a year after Executive Order 14105,...more

Sheppard Mullin Richter & Hampton LLP

SoL Long to Short Limits: The Sequel — A Decade of Recordkeeping and Enforcement

On July 22, 2024, the Department of Treasury, Office of Foreign Assets Control (OFAC) announced a significant planned extension to its recordkeeping requirements, which will increase the retention period from five to ten...more

Paul Hastings LLP

Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments

Paul Hastings LLP on

Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more

Morrison & Foerster LLP

New Sheriff in Town: Treasury Proposes Unprecedented Outbound Investment Screening Regulations

On June 21, 2024, the Biden administration rolled out its outbound investment screening regulations. Last year, the Biden administration published an advanced notice of proposed rulemaking (ANPRM) that outlined the broad...more

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