Sanctions

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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…

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…

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…

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 23, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a notice about new reporting requirements (the OFAC Reporting Notice) under the Rebuilding Economic Prosperity and Opportunity for Ukrainians Act (REPO for Ukrainians Act).  As discussed in our previous client alert, the REPO for Ukrainians Act authorizes…

In this session, hosts and International Trade Practice Leaders Nicole Simonian and Dj Wolff talk with Crowell lawyers Jeremy Iloulian and Laurel Saito about the significant new sanctions and export control authorities included in the recently enacted National Security Supplemental fiscal package. While this legislation is best known for providing U.S. foreign aid commitments for…

The latest U.S. foreign aid bill supporting Ukraine, Israel, and Taiwan enacted on April 24, 2024 enhances U.S. sanctions and export controls including expanding (1) the statute of limitations for sanctions violations; (2) the President’s authority to coordinate sanctions efforts with the European Union and the United Kingdom; (3) sanctions and export controls on Iran…

On Thursday, April 18, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new sanctions on Iran following its April 13, 2024 attack on Israel. OFAC designated 16 individuals and ten entities as Specially Designated Nationals and Blocked Persons (SDN), specifically those involved in Iran’s unmanned aerial vehicle (UAV), steel, and…

On March 6, 2024, the Department of Commerce, the Department of the Treasury, and the Department of Justice published a Tri-Seal Compliance Note titled “Obligations of foreign-based persons to comply with U.S. sanctions and export control laws” (the “Note”). The Note stresses that U.S. persons are not the only entities subject to U.S. sanctions and…

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…