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Haynes Boone

World Bank Reconsiders Nuclear Finance

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Under mounting pressure from advocates and stakeholders—most prominently the United States government—the World Bank recently rescinded its longstanding ban on financing nuclear power projects and announced its plan to...more

Foley & Lardner LLP

FinCEN Exercises New Authority Targeting Mexico-Based Financial Institutions to Counter Cartel-Linked Fentanyl Trade

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On June 25, 2025, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury designated three Mexico-based financial institutions as primary money laundering concerns under Section 311 of the USA...more

Patomak Global Partners

Significant U.S. Sanctions Relief for Syrian Arab Republic

The United States had imposed layers of sanctions on Syria since deeming it a State Sponsor of Terrorism in 1979. The U.S. Treasury imposed most sanctions during the Iraq War and the Syrian Civil War. In December 2024, Hay’at...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

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

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

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

Benesch

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

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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

K2 Integrity

Quick Take: United States To Lift Sanctions Against Syria

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On 13 May 2025, U.S. President Donald Trump announced that his administration will start “restoring the normal relationship” with Syria’s new government and “ordering the cessation of sanctions against Syria.” While, at the...more

Ballard Spahr LLP

Cracking Down on CJNG: FinCEN’s Alert and OFAC’s Strategic Sanctions on Oil Smuggling

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In a significant move to curb illegal activities at the U.S. Southwest border, the Financial Crimes Enforcement Network (FinCEN) issued an alert, on May 1, 2025, concerning oil smuggling from Mexico into the United States,...more

Paul Hastings LLP

A Whirlwind of Change: The Delisting of Tornado Cash

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Over the past several years, as U.S. regulators have grappled with the increasing use of cryptocurrency across a spectrum of legitimate and illegitimate commerce, the U.S. Department of Commerce’s Office of Foreign Assets...more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

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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

Troutman Pepper Locke

Financial Transactions Related to Russian Energy Now Prohibited: Expiration of OFAC ‎General License 8L

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On March 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) allowed General License (GL) 8L under the Russian Harmful Foreign Activities Sanctions Regulations to expire. As a result, broad OFAC...more

A&O Shearman

Widening the sanctions net in uncertain times: latest developments in the U.S., EU, and U.K.'s sanctions targeting Russia

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In the context of the third anniversary of Russia’s invasion of Ukraine, the U.S., EU, and U.K. continue to implement new measures to stifle Russia’s war efforts. The Biden administration continued to escalate sanctions...more

Troutman Pepper Locke

Latest Sanctions Developments: Venezuela, Russia, and Yemen

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The Trump administration continues to ramp up sanctions on Venezuela and Yemen's Houthis, while sending mixed signals about its intentions with respect to Russia. We provide brief updates on these three areas, following up...more

Faegre Drinker Biddle & Reath LLP

Trump Administration’s America First Investment Policy to Bring Changes to CFIUS and Outbound Investment Reviews

Below is a summary of some of the measures identified in the Policy, and some suggestions for what foreign and domestic investors should be considering as this goes into effect....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

Hogan Lovells

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

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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

Guidepost Solutions LLC

Mexican Cartels as Foreign Terrorist Organizations: A New Era of Risk for Global Businesses

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.” This directive instructs the...more

Morgan Lewis

OFAC Issues Syria General License and FAQs Easing Sanctions

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The US Office of Foreign Assets Control (OFAC) issued Syria General License 24 (GL 24) authorizing certain transactions with the new Syrian government and easing some transactions related to energy and personal remittances....more

Bracewell LLP

Biden Administration Issues Sweeping Salvo of Sanctions Against the Russian Energy Sector

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On January 10, 2025, in a final action to, among other things, deter Russian aggression on the international stage, the US Department of the Treasury enacted sweeping new sanctions on the Russian energy sector. Specifically,...more

BCLP

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

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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

Hogan Lovells

Significant new measures against Russia issued by US Departments of Treasury, State, and Commerce

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On 12 June 2024, the US Departments of Treasury, State, and Commerce imposed new restrictions targeting Russia, including: (i) restricting the provision of certain information technology and software services to Russia...more

Pillsbury - Global Trade & Sanctions Law

Treasury Amends the Cuban Assets Control Regulations to Support Cuban Citizens and Independent Private Sector Entrepreneurs

On May 28, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR) to better implement the Biden-Harris Administration’s policy aimed at...more

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