Office of Foreign Assets Control (OFAC)

On January 13, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated “two organizations, along with their leaders and subsidiaries, controlled by the Supreme Leader of Iran, the Execution of Imam Khomeini’s Order (EIKO), and Astan Quds Razavi (AQR).”

Although both purported to be charitable organizations (bonyads), Treasury states, “EIKO and

This week the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published three Frequently Asked Questions (FAQ) related to Executive Order (E.O.) 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies.”

  • Can U.S. persons custody, offer for sale, serve as a transfer agent, and trade in covered securities?

For purposes

On December 7, 2020, The Council of the European Union adopted a global human rights sanctions regime, similar to the Magnitsky Sanctions program used by the Department of the Treasury’s Office of Foreign Assets Control (OFAC). The EU’s framework will permit it to target individuals, entities, and bodies, whether state or non-state actors, and

On November 19, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) designated two entities operating in Russia determined to be involved in the exportation of forced labor from North Korea, under the authority of Executive Order (E.O.) 13722 of March 15, 2016, “Blocking Property of the Government of North Korea and the

On November 30, 2020, the U.S. Customs and Border Protection (“CBP”) placed all cotton and cotton products from Xinjiang Production and Construction Corporation (“XPCC”) and its subordinate and affiliated entities on the Withhold Release Orders (“WRO”) list. XPCC is a Chinese state-owned enterprise (“SOE”) which produces around 17 percent of the Xinjiang’s cotton and

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

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

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