On March 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated the “teapot” Chinese oil refinery Shandong Shouguang Luqing Petrochemical Co., Ltd. (“Luqing Petrochemical”), its chief executive officer, eight vessels, and eleven vessel owners, managers, and operators, on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”).
Sanctions Compliance
OFAC Issues Necessary and Long-Awaited Updated Guidance for (Re)Insurance Industry
On November 13, 2024, the U.S. Department of the Treasury’s (“Treasury’s”) Office of Foreign Assets Control (“OFAC”) updated its FAQs for insurers in a long-awaited move to modernize its published sanctions compliance guidance for the insurance industry. None of the industry-specific FAQs had been updated since January 2015, and many had not been amended in…
Aid and Sanctions: Ukraine, Israel, and Taiwan Aid Bill Expands U.S. Sanctions and Export Control Authorities
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…
Commerce, Treasury, DOJ Publish Tri-Seal Sanctions and Export Control Compliance Note
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…