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U.S. Treasury Office of Foreign Assets Control (OFAC)

The Volkov Law Group

Episode 378 — Update on Export and Sanctions Enforcement Cases

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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

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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

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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

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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

Foley & Lardner LLP

What U.S. Businesses Need to Know About Reentering the Syrian Market & the Changing Post-Assad Sanction Landscape

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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

Fenwick & West LLP

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

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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

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

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

Akin Gump Strauss Hauer & Feld LLP

Providing For the Revocation of Syria Sanctions (Trump EO Tracker)

Orders the termination of prior Syria-related sanctions effective July 1, 2025, while directing the Secretaries of State, Treasury, and Commerce to implement new authorities that both provide targeted sanctions relief and...more

The Volkov Law Group

OFAC Returns to Enforcement Scene — GVA Capital Pays $215 Million Penalty for Violations of Ukraine/Russia-Sanctions

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The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been relatively quiet on the enforcement front. That is not unusual — every transition results in an enforcement hiatus. Sanctions enforcement is a...more

Bressler, Amery & Ross, P.C.

NY Department of Financial Services Issues Guidance to its Regulated Industry As a Result of the Ongoing Global Conflict

The New York State Department of Financial Services (the “Department”) has issued guidance (“Guidance”) to all individuals and entities regulated by the Department (“Regulated Entities”) to underscore the importance of...more

Husch Blackwell LLP

Week Twenty in Trade

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On June 20, 2025, U.S. Customs and Border Protection (“CBP”) announced it is deploying the Forced Labor Allegation Portal, which allows users to submit forced labor allegations. Submissions may be made anonymously and may...more

Holland & Knight LLP

FinCEN Advisory Highlights Iran Sanctions Evasion Red Flags

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The U.S. Department of the Treasury's (Treasury) Financial Crimes Enforcement Network (FinCEN), published the FinCEN Advisory on the Iranian Regime's Illicit Oil Smuggling Activities, Shadow Banking Networks, and Weapons...more

Lowenstein Sandler LLP

OFAC Imposes Largest-Ever Penalty on Nonbank Financial Institution for Egregious and Sustained Sanctions Violations—a $216M...

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a historic $215,988,868 civil monetary penalty against GVA Capital Ltd. (GVA), a venture-capital firm registered in the Cayman Islands...more

Morgan Lewis

OFAC Action Shows Risk of Not Recognizing That ‘Property Interests’ Include ‘Any Interest Whatsoever’

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The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) fined GVA Capital Ltd. $215 million, primarily for violating the Ukraine/Russia-related sanctions regulations, when GVA mistakenly concluded that it...more

Vinson & Elkins LLP

Commercial Considerations Related to the Shift in Syrian Sanctions Policy

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On May 23, 2025, General License 25 (“GL 25” or the “General License”) was issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), suspending a wide array of sanctions against Syria....more

Morrison & Foerster LLP

Trump Administration Issues Broad Sanctions Relief for Syria, Effectively Lifting 14 Years of Comprehensive Economic Sanctions –...

On May 23, 2025, 10 days after President Trump announced his directive to lift U.S. sanctions on Syria during his visit to Saudia Arabia last month, the U.S. Department of the Treasury’s Office of Foreign Assets Control...more

Amundsen Davis LLC

How to Be Removed From a U.S. Sanctions Watchlist List

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U.S. sanctions are a powerful tool used to influence the behavior of foreign governments, individuals, and entities. Placement on any sanctions watchlist maintained by a regulatory agency can have devastating financial,...more

K2 Integrity

Sanctions Relief For Syria: The United States And European Union Offer Broad Sanctions Relief To Syria

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Building on the Quick Take Alert K2 Integrity published on 15 May 2025, this alert outlines the recent developments regarding the easing of Syria sanctions. While the United States has not fully lifted its Syria sanctions, it...more

Baker Botts L.L.P.

Congress Readies Sweeping Bipartisan Sanctions Bill Targeting Russia and Its Trading Partners

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In response to Russia’s ongoing invasion of Ukraine, lawmakers in both chambers of Congress have introduced legislation aimed at penalizing Russia through the imposition of sanctions and other economic measures. The...more

The Volkov Law Group

OFAC Recalibrates Syria Sanctions in Response to Regime Change

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On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 25 under the Syrian Sanctions Regulations, marking a measured but far-reaching reconfiguration of...more

ArentFox Schiff

So Long Syria Sanctions? Not So Fast!

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On May 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25, “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain...more

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