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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
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
February saw a continuing focus on Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the State Department, sanctioned over 500 individuals and entities – the “largest number...more
July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more
The first-ever tri-seal Note highlights tactics used to circumvent Russia-related restrictions, while NSD adds 25 prosecutors focusing on sanctions and export controls. In May 2022, shortly after hostilities in Ukraine...more
As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations. In another unprecedented action, the Justice Department and the...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more