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On September 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it is seeking comments on a new interim final rule amending OFAC’s Reporting, Procedures and Penalties Regulations to extend recordkeeping requirements from five to ten years.  While OFAC is seeking comments within 30 days, the interim final rule…

On August 23rd, 2024, the U.S. Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State (State), and the Commerce Department’s Bureau of Industry and Security (BIS) acted against Russia’s international supply chains.

OFAC and State collectively sanctioned nearly 400 individuals and entities. Of note, this included a substantial focus on…

On July 22, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released guidance (“Guidance”) on how it will implement the new authority it was granted in the April 24, 2024 National Security Supplemental (“the Act”).  The Act extended the statute of limitations for civil, criminal, and forfeiture violations of sanctions…

An overview on new Russian sanctions and export controls issued by the European Union, focusing on anti-circumvention measures and the Russian financial, military, and LNG industries.

Click here to continue reading the full version of this alert.

An overview on new Russian sanctions and export controls issued by the U.S. (OFAC and BIS) and the UK focusing on the Russian financial, military, and LNG industries.

Click here to continue reading the full version of this alert.

On Tuesday, the U.S. Department of Commerce Bureau of Industry and Security’s Office of Antiboycott Compliance (OAC) issued an advisory regarding the Turkish government’s announcement that it will “suspend all exports and imports to and from Israel until the Israeli government allows an uninterrupted and sufficient flow of humanitarian aid into Gaza.”

The…

On May 1, 2024, the UK’s financial sanctions regulator – the Office of Financial Sanctions Implementation (“OFSI”) – launched a new Frequently Asked Quesstion service, setting out consolidated responses to frequently asked questions about UK financial sanctions. 

Russia is the key focus, with FAQs dedicated to the UK’s asset freezing sanctions, other financial…

Earlier this week, the U.S. government partially re-implemented certain recently relaxed sanctions against Venezuela. According to a statement released by the United States Department of State on January 30th, the absence of meaningful progress in allowing candidates of the opposition Unitary Platform to stand for office in the upcoming Venezuelan presidential election has…

On January 17, 2024, the US Department of the Treasury (“Treasury”) Office of Foreign Assets Control (“OFAC”) announced the re-addition of Ansarallah, better known as the Houthis, to the List of Specially Designated Nationals and Blocked Persons (“SDN List”) as a Specially Designated Global Terrorist, just shy of three years after delisting the group to…

Last week, OFAC announced it is increasing its maximum amount of the civil monetary penalties (CMP) that may be assessed under relevant OFAC regulations by implementing the Federal Civil Penalties Inflation Adjustment Act of 1990 for 2024. These increases adjust for inflation and have occurred nine times since 2015. The changes to the CMPs are…