Office of Foreign Assets Control (OFAC)

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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”)…

Crowell & Moring Monthly Webinar Series

Tuesday, June 23, 2020

12:00 – 1:30 pm EDT

In the past several years, the U.S. government has issued a series of sweeping Executive Orders, policy announcements, and other regulatory and enforcement actions as part of a multi-pronged approach to protect U.S. national interests against the perceived challenges a…

On June 5, 2020, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published four new Frequently Asked Questions (“FAQs”) related to Executive Order 13902 (“EO 13902”) that may be particularly insightful for those companies that still do business involving Iran. The EO, first issued on January 10, 2020, imposed, in part, additional…

On May 14, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State, and the U.S. Coast Guard issued a long-awaited “Sanctions Advisory for the Maritime Industry, Energy and Metals Sectors, and Related Communities” (the “Advisory”). The Advisory substantially expands on previous shipping advisories that…

In response to criticism that sanctions are hampering the global response to the COVID-19 pandemic, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released new guidance to encourage those interested in humanitarian trade involving jurisdictions sanctioned by the United States to “avail themselves of longstanding exemptions, exceptions, and authorizations” pertaining to that…

Keeping pace with the rapidly changing geopolitics in the region, the last week has brought a series of Iran-related sanctions developments with which global businesses need to keep up.  First, on January 10, the United States further escalated sanctions against Iran, creating new designation authorities for those “operating in” Iran’s construction, mining, manufacturing, and textile…

On December 31, 2019, a federal district court in Texas (the “District Court, or “Court”) overturned  a $2 million fine levied by the Office of Foreign Assets Control (“OFAC”) against Exxon Mobil Corporation (“Exxon”) for alleged violations of the Ukraine-Related Sanctions Regulations (“URSR”).    OFAC had assessed that Exxon received a prohibited service from a designated…

On October 14, 2019, the Trump Administration followed through on its recent threats by issuing a new Executive Order (EO) (as yet unnumbered) establishing sanctions that effectively target the Turkish Government in response to the latter’s military intervention into Northern Syria. Using this authority, the U.S. Department of the Treasury’s Office of Foreign Assets Control…

On September 20, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control designated the Central Bank of Iran, the National Development Fund of Iran, and the Etemad Tejarat Pars Co. under Executive Order 13224, OFAC’s counter-terrorism authority (E.O. 13224). The U.S. pointed to attacks on Saudi Arabia’s oil fields as the catalyst for…

On September 9, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) published amendments to the Cuban Assets Control Regulations (the “Cuba Sanctions”) to limit “U-turn” transactions and remittances.

“U-turn” transaction is a reference to a Cuba Sanctions authorization (31 CFR § 515.584(d)) for banking institutions subject to U.S. jurisdiction to process…