On April 14, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government of Venezuela” (GL 56), and Venezuela General License 57, “Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals” (GL
Carlton Greene
Carlton Greene is a partner in Crowell & Moring's Washington, D.C. office and a member of the firm's International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.
OFAC Sanctions Cartel-Linked Casinos and Financial Enablers on the Southern Border
- The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated six individuals and entities tied to Cartel del Noreste (CDN)—one of Mexico’s most violent drug trafficking organizations—including two CDN-affiliated casinos used for money laundering and drug operations near the U.S.-Mexico border.
- OFAC’s actions are the latest examples of a broader
Eight Takeaways After Seven Weeks of OFAC’s Six, wait Seven, New and Updated General Licenses for Venezuela
Introduction
Over the last two months, OFAC has issued and updated a series of general licenses and Frequently Asked Questions (FAQs) that allow for a variety of activities in the Venezuela oil, gas, petrochemical products, electricity, and gold sectors when they involve persons sanctioned pursuant to the Venezuela sanctions regulations, including the Government of Venezuela…
Key Takeaways from a Consequential Month of Russia-Related Sanctions
The United States, European Union, and United Kingdom have significantly escalated Russia-related sanctions the past month, including the Trump Administration’s first sanctions directly imposed on Russia. These coordinated actions—which particularly target the Russian energy sector—indicate that Russia sanctions remain on the geopolitical agenda and require multinational companies to remain vigilant in their compliance with those…
Focus on Transnational Cartels Continues: FinCEN Targets Three Mexican Financial Institutions with Special Measures, Restricting Their Access to U.S. Financial System
Reflecting the administration’s continued focus on transnational cartels, on June 25, 2025, FinCEN identified three Mexican financial institutions as “primary money laundering concerns,” and imposed restrictions on U.S. financial institutions from engaging in transactions with these entities.
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Client Alert: U.S. Departments of State and Treasury Issue Immediate Sanctions Relief for Syria
On May 23, 2025, the U.S. Departments of State (“State”) and the Treasury (“Treasury”) took actions that resulted in immediate sanctions relief for Syria. Specifically, Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License 25 (“GL 25”) pursuant to the Syrian Sanctions Regulations (“SySR”), the Weapons of Mass Destruction Proliferators Sanctions Regulations (“NPWMD”), the…
Client Alert: DOJ Reprioritizes Corporate Enforcement with Key Policy Revisions
In a May 12, 2025 speech that signaled both a recalibration of and recommitment to prosecuting white-collar crime, Matthew R. Galeotti, the newly appointed Head of the Department of Justice’s Criminal Division, said that the Division is “turning a new page” and embracing an enforcement approach that aims to elevate efficiency, predictability, and fairness. The…
Firms at Risk of Monetary Penalty for Breaches of UK Financial Sanctions Imposed on Russia
The UK’s Office of Financial Sanctions Implementation (“OFSI”) has imposed a monetary penalty of £465,000 against a multinational law firm’s Russian office (the “Russian Office”) for breaching UK financial sanctions against Russia following its invasion of Ukraine in February 2022. This is the first time OFSI has enforced against a law…
Client Alert: Coalition of the Willing: EU and UK, but Not the US, Impose New Russia Sanctions
As they have on each previous anniversary, the EU and UK released new sanctions against Russia on February 24, 2025, to mark the three-year anniversary of Russia’s full-scale invasion of Ukraine. For the first time, the United States did not do the same, electing to issue a limited set of Iran-related sanctions on the anniversary…
Parting Shots by Biden Administration in the Form of Sweeping New Russia Sanctions
- On the 10th, OFAC and the State Department aggressively targeted the Russian energy sector by designating major Russian oil companies liquefied natural