On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated the “teapot” Chinese oil refinery Shandong Shouguang Luqing Petrochemical Co., Ltd. (“Luqing Petrochemical”), its chief executive officer, eight vessels, and eleven vessel owners, managers, and operators, on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”).

Erik Woodhouse
Erik Woodhouse is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Financial Services groups, where he provides in-depth experience and practical solutions on sensitive economic sanctions and anti-money laundering matters, informed by his experience in private practice and in government at the Department of the Treasury and the Department of State.
Erik works with U.S. and foreign clients operating across borders on all aspects of these regimes, including developing and assessing compliance programs, advising on complex statutory and regulatory requirements, and leading companies through internal and government investigations. He has worked with major manufacturing and tech companies with global operations, multinational banks, investment funds and other financial services firms, and digital assets and virtual currency companies, collaborating with Crowell’s cross-disciplinary team that comprises former senior regulators, federal prosecutors, and in-house counsel.
Prior to joining Crowell, Erik served as Deputy Assistant Secretary of State for Counter Threat Finance and Sanctions at the Department of State, where he played a key role in the Department’s policy development and implementation related to all U.S. country-based sanctions programs and a range of global programs. Erik worked with counterparts across the executive branch to establish and implement new sanctions programs, coordinated U.S. sanctions policy with foreign governments, and engaged with private sector stakeholders on a range of U.S. sanctions priorities. Erik’s prior government experience also includes service at the Department of the Treasury’s Office of International Affairs.
Earlier in his career, Erik worked as a project finance attorney and litigator, as a law clerk for the Honorable M. Margaret McKeown of the U.S. Court of Appeals for the Ninth Circuit, and as a research fellow at Stanford University’s Program on Energy & Sustainable Development.
President Trump’s Executive Orders & Actions – Sanctions
President Trump signed a raft of Executive Orders (E.O.) in the initial days of his new administration, several of which relate to sanctions. Here is an initial run-down:
Designating Cartels as Foreign Terrorist Organizations
On January 20, the President signed an executive order that creates a process for cartels and “other transnational organizations such…
Parting Shots by Biden Administration in the Form of Sweeping New Russia Sanctions
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of State issued new Russia sanctions on January 10th and 15th, 2025.
- On the 10th, OFAC and the State Department aggressively targeted the Russian energy sector by designating major Russian oil companies liquefied natural
OFAC Issues New Syria General License and Updates FAQs
On January 6, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License 24, which authorizes transactions with governing institutions in Syria and certain activities related to energy and personal remittances. OFAC explained it issued General License 24 in light of the collapse of Bashar al-Assad’s government and…
Global Trade Talks: Welcome Back Erik Woodhouse: Initial Thoughts on the Sanctions Landscape Under Trump 2.0
Erik is returning to Crowell after serving as the Deputy Assistant Secretary for the Division for Counter Threat Finance and Sanctions, Bureau of Economic and Business Affairs, U.S. Department of State. This episode discusses Erik’s experience at Department of State and how that informs his practice at Crowell, and his thoughts on possible developments under…
OFAC Targets Iran’s Financial Sector and Designates Additional Iranian Banks
On October 8, 2020, the Treasury Department’s Office of Foreign Assets Control (OFAC) took a long-rumored final step in curtailing virtually all non-humanitarian financial flows with Iran, identifying the Iranian “financial sector” as a target for potential “secondary” sanctions designation, and simultaneously designating eighteen Iranian financial institutions, many of which had been the only…
OFAC and FinCEN Release Advisories on Risks of Ransomware Payments
On October 1, 2020, the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) each released advisories (the OFAC Advisory and the FinCEN Advisory) addressing financial crime-related risks associated with ransomware and ransomware payments. The OFAC Advisory focuses on the risk that ransomware attacks or payments may involve sanctioned persons…
FinCEN Issues ANPRM Seeking Comment on Requirement for an “Effective and Reasonably Designed” AML Program
On September 16, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued an advanced notice of rulemaking (“ANPRM”) requesting comments on proposed regulatory changes under the Bank Secrecy Act (“BSA”) that aim to enhance the effectiveness of anti-money laundering (“AML”) programs. The proposals reflect the recommendations of a working group within the Bank Secrecy Act Advisory…
FinCEN Issues Alert to Financial Institutions Regarding Scam Involving Twitter
On July 16, 2020, the Financial Crimes Enforcement Network (FinCEN) issued an alert to financial institutions emphasizing a recent scam exploiting Twitter accounts to fraudulently solicit virtual currency payments. The cyber threat actors involved in the scam compromised accounts of various public figures, organizations, and financial institutions in an attempt to solicit virtual currency payments…
Creation of a New Hong Kong-Related Sanctions Program
On July 14th, President Trump signed into law the Hong Kong Autonomy Act (the “Act”) that Congress unanimously passed earlier this month, and simultaneously issued an as-yet-unnumbered Executive Order (the “HK EO”) that implements many of its provisions. These actions follow the June 30th imposition by the government of the People’s Republic of China (“China”)…