On March 2, 2021, the Biden Administration announced the intelligence community’s finding that Russia’s Federal Security Service (FSB) used a banned chemical nerve agent to poison Russian opposition leader, Aleksey Navalny.  Shortly following the White House’s press briefing, the Departments of State, Commerce, and Treasury issued press releases announcing new sanctions and export controls, summarized

Less than three weeks after the group’s initial addition to the list of Foreign Terrorist Organizations, the Biden administration removed Ansarallah (the Houthis in Yemen) from the list on February 16, 2021.  As a result, Ansarallah is no longer blocked pursuant to OFAC’s Global Terrorism Sanctions Regulations and U.S. persons do not require authorization from

In the first material sanctions-related action of the new U.S. Administration, on February 11, 2021, President Biden issued Executive Order 14014 (EO) imposing sanctions on Myanmar (Burma) in response to the February 1, 2021, military coup and subsequent detention of government leaders, politicians, and others there. The sanctions focus on the defense sector of the

On January 27, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 1A, “Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies,” (“GL 1A”) which amends and replaces General License 1 that had been initially issued on January 8, 2021.  OFAC has also published related frequently asked

The incoming Biden administration faces a number of serious international trade issues, including increased tensions with China, the implementation of Brexit, and last, but far from least, a global pandemic that continues to impact global supply chains, mobility, and many other aspects of our interconnected world. Join us as we identify these issues along with

According to a January 19 press release, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) “designated three individuals, fourteen entities, and six vessels for their ties to a network attempting to evade United States sanctions on Venezuela’s oil sector.” According to OFAC, the  Maduro regime is continuing to use “Petroleos

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 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 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”)