Sanctions

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The UK’s Office of Financial Sanctions Implementation (OFSI) has published details of a £390,000 penalty it imposed on ADI, an Irish subsidiary of Apple Inc., on 19 March 2026. The penalty relates to two payments totalling approximately £635,000 made in 2022 to Okko LLC, a sanctioned Russian app developer, for App Store revenue. Although the…

On March 26, 2026, the Senate Judiciary Committee advanced S.2934, the Protecting Americans from Russian Litigation Act of 2025 (the Bill), introduced by Senators John Cornyn (R-TX) and Alex Padilla (D-CA) in September 2025. The Bill is intended to address situations where U.S. companies that exited Russia to comply with U.S. sanctions following Russia’s…

On March 18 and 19, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two new Venezuela-related general licenses: General License No. 52 (GL 52), authorizing most previously prohibited transactions involving Petróleos de Venezuela, S.A. (PdVSA)  and General License No. 5V (GL 5V), authorizing further transactions related to the…

Introduction

Over the last two months, OFAC has issued and updated a series of general licenses and Frequently Asked Questions (FAQs) that allow for a variety of activities in the Venezuela oil, gas, petrochemical products, electricity, and gold sectors when they involve persons sanctioned pursuant to the Venezuela sanctions regulations, including the Government of Venezuela…

In what amounts to a material expansion of its existing sanctions program arising out of the conflict in the Democratic Republic of the Congo (“DRC”), on March 2, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions against the Rwanda Defence Force (“RDF”)—an organization described by OFAC as Rwanda’s…

On February 6, 2026, the U.S. Department of Treasury’s Office of Foreign Assets Controls (OFAC) announced the launch of a new online Voluntary Self-Disclosure (VSD) Portal (the “New Portal”) intended to replace and reduce reliance on ad hoc submission methods with a more secure channel for reporting to OFAC potential sanctions violations. OFAC states that…

On January 21, 2026, the U.S. Office of Foreign Assets Control (OFAC) announced the removal of Greek maritime company Altomare SA and its vessel, Kallista, from the Specially Designated Nationals and Blocked Persons Lists (SDN List).

OFAC originally designated Altomare SA and Kallista in November 2025 as part of a counter terrorism sanctions action…

In issuing the Affiliates Rule with immediate effect, the U.S. Department of Commerce Bureau of Industry and Security (BIS) drastically expanded the number of entities subject to the BIS’ most restrictive export tools by applying the same trade prohibitions to any entities that are owned, directly or indirectly, 50 percent or more by one or…

On May 23, 2025, the U.S. Departments of State (“State”) and the Treasury (“Treasury”) took actions that resulted in immediate sanctions relief for Syria. Specifically, Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License 25 (“GL 25”) pursuant to the Syrian Sanctions Regulations (“SySR”), the Weapons of Mass Destruction Proliferators Sanctions Regulations (“NPWMD”), the…